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Rule 108: APL-01 Filing and the Date of Filing

The provisional acknowledgement fixes the date — but only if the order was on the portal. Where it was not, seven days decide whether the appeal is in time.

Vikas Sharma Tax & Compliance Expert
5 min read 6 views Updated Sep 6, 2026 Expert Reviewed Medium Complexity
Rule 108: APL-01 Filing and the Date of Filing
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Last updated: September 2026Verified against: Government sources
Quick Answer

The provisional acknowledgement fixes the date — but only if the order was on the portal. Where it was not, seven days decide whether the appeal is in time.

An appeal filed on the last day is in time or out of time depending on a rule about acknowledgements. It is worth understanding before the last day.

Two paths, two dates

Order uploaded on the portalOrder not uploaded
FileAPL-01 electronicallyAPL-01 electronically
ImmediatelyProvisional acknowledgementProvisional acknowledgement
Additional stepNoneSelf-certified copy of the order within seven days
Final acknowledgementAPL-02 with the appeal numberAPL-02 after the copy is submitted
Date of filingDate of the provisional acknowledgementGoverned by the sub-rule's scheme — the seven days matters

The practical rule: where the order is on the portal, the appeal is filed the moment the APL-01 goes in. Where it is not, the seven-day step is not optional — it is what completes the filing.

When the order is not on the portal

This is more common than it sounds. Orders are sometimes served by hand, by email or by post without being uploaded, and orders passed by State authorities or in older periods may not appear.

What to do:

  1. Check the portal first — the notices and orders tab, under the correct GSTIN and period.
  2. If it is not there, say so in the APL-01 and be ready with the self-certified copy.
  3. File the APL-01 well before the deadline, so the seven days for the copy falls inside the appeal period rather than outside it.
  4. Submit the self-certified copy within seven days of filing, and keep proof.
  5. Obtain the APL-02 with the appeal number, and treat that as confirmation the appeal is on record.

The trap: filing the APL-01 on the last of the four months, with the order off-portal, and submitting the copy a fortnight later. The safe assumption is that the appeal is late.

When manual filing is available

The proviso to Rule 108(1): an appeal may be filed manually in FORM GST APL-01, with the relevant documents, only if:

  • (i) the Commissioner has so notified; or
  • (ii) it cannot be filed electronically due to non-availability of the decision or order to be appealed against on the common portal,

and in such case a provisional acknowledgement shall be issued immediately.

So manual filing is not a general option. It requires either a notification or the specific portal-unavailability ground — and the second ground concerns the order not being on the portal, not the portal being generally unavailable.

Where manual filing is used, retain the inward acknowledgement with its date and, if possible, a dated receipt — the provisional acknowledgement is what evidences the filing date.

Signing: Rule 26

Rule 108(2) requires the grounds of appeal and the form of verification to be signed in the manner specified in Rule 26 — a digital signature certificate for a company or an LLP, and a DSC or e-signature for other classes of person.

A common failure: the appeal is filed by a consultant using their own credentials, or the verification is signed by a person not authorised on the portal for that GSTIN. Both invite an objection at admission. The authorised signatory on the registration should be the person signing, or a properly authorised representative under s.116. Section 116 →

What to file with the APL-01

Required:

  • the impugned order (self-certified copy where not on the portal);
  • the grounds of appeal;
  • the statement of facts;
  • the verification, signed as Rule 26 requires;
  • proof of the pre-deposit under s.107(6) — the challan and, where paid through DRC-03, the ARN.

Worth filing:

  • the show cause notice and its annexures;
  • the reply filed and its annexures;
  • the record of the personal hearing and any written submissions made at it;
  • the relied-upon documents the department used;
  • the computation disputing quantum;
  • an index, paginated, so the Appellate Authority can find things.

The appeal record should stand on its own. An Appellate Authority reading only the impugned order and the grounds sees the department's version of the case. Drafting the grounds of appeal →

Key takeaways

  • APL-01 electronically, with a provisional acknowledgement issued immediately.
  • Where the order is on the portal, the date of the provisional acknowledgement is the date of filing.
  • Where it is not, a self-certified copy within seven days completes the filing — do not leave it to the last day.
  • Manual filing only where the Commissioner has notified it or the order is not on the portal.
  • Sign as Rule 26 requires, through the authorised signatory or a proper representative.
  • File the full record — notice, reply, hearing submissions, relied-upon documents and the pre-deposit proof.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition).

Key Facts About Rule 108

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

In which form is a first appeal filed?

FORM GST APL-01, electronically, with the relevant documents, under Rule 108(1).

What is the date of filing?

Where the order appealed against is uploaded on the common portal, the date of the provisional acknowledgement. Where it is not, the seven-day requirement for the self-certified copy governs.

Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.

— TaxClue Compliance Desk

Rule 108: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

Related Services & Guides

Frequently Asked Questions
In which form is a first appeal filed?
FORM GST APL-01, electronically, with the relevant documents, under Rule 108(1).
What is the date of filing?
Where the order appealed against is uploaded on the common portal, the date of the provisional acknowledgement. Where it is not, the seven-day requirement for the self-certified copy governs.
What if the order is not on the portal?
Submit a self-certified copy of the order within seven days of filing the APL-01, after which the final acknowledgement in APL-02 is issued.
When can an appeal be filed manually?
Only where the Commissioner has notified manual filing, or where electronic filing is not possible because the order is not available on the common portal.
Who should sign the appeal?
The person authorised in the manner specified in Rule 26 — the authorised signatory on the registration, or a representative authorised under section 116.
What is FORM GST APL-02?
The final acknowledgement indicating the appeal number, issued by the Appellate Authority or an authorised officer.

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Vikas Sharma VERIFIED EXPERT
7431 articles
Tax & Compliance Expert
Experienced in company registration, GST, trademark, and compliance. Helping Indian businesses stay compliant.
Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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