Rule 110: APL-05, APL-02A and GSTAT E-Filing

Rule 110 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

The Tribunal's filing rules were rewritten in September 2025. Three changes matter: filing is electronic, the acknowledgement form changed, and the manual escape routes were removed.

Rule 110, as substituted by Notification No. 13/2025-CT dated 17.09.2025, w.e.f. 22.09.2025: an appeal under s.112(1) shall be filed in FORM GST APL-05, with the relevant documents, electronically, and a provisional acknowledgement in Part A of FORM GST APL-02A issued immediately; the manual-filing proviso was omitted. A memorandum of cross-objections in FORM GST APL-06, electronically; its manual-filing proviso was likewise omitted. Signing per Rule 26. Where the order is uploaded on the portal, the final acknowledgement in Part B of FORM GST APL-02A issues; where it is not, a self-attested copy is submitted and the date of its submission or uploading is the date of filing. Explanation 1: the appeal is treated as filed only when the final acknowledgement indicating the appeal number is issued.

What Notification 13/2025-CT changed

The direction of travel is clear: a fully electronic Tribunal filing system, with a single two-part acknowledgement form replacing the shared APL-02 used at the first-appeal stage.

The date of filing, and Explanation 1

Two rules operate together and they must be read together.

Where the order appealed against is uploaded on the common portal: the final acknowledgement in Part B of APL-02A is issued, and the filing follows the ordinary course.

Where the order is not uploaded: the appellant submits a self-attested copy, and the date of submission or uploading of that copy shall be considered as the date of filing of the appeal — after removal of defects, if any.

Explanation 1 then governs everything: "the appeal shall be treated as filed only when the final acknowledgement, indicating the appeal number, is issued."

The practical consequence for limitation:

• do not treat the Part A provisional acknowledgement as the end of the filing exercise;
• where the order is off-portal, submit the self-attested copy immediately, because that date is the date of filing;
• remove defects promptly, because the date runs after their removal;
• keep the Part B acknowledgement with the appeal number — that is the proof the appeal is on record.

An appeal filed on the last available day, with an off-portal order and a copy submitted a week later, is late.

The earlier version of Rule 110, and why it still matters

The rule as it stood before the substitution required:

• filing in APL-05 electronically or otherwise as notified by the Registrar;
• a certified copy of the decision or order with the fees, submitted to the Registrar within seven days of filing;
• a final acknowledgement in APL-02 thereafter;
• and a proviso: where the certified copy was submitted within seven days, the date of filing was the date of the provisional acknowledgement; where after seven days, the date of filing was the date of submission of the copy.

Rule 110(5) in that version set the fees: one thousand rupees for every one lakh rupees of tax or input tax credit involved, or the difference in either, or the amount of fine, fee or penalty determined in the order appealed against, subject to a maximum of twenty-five thousand rupees — for filing or restoration of an appeal.

Why it still matters: appeals filed before 22.09.2025 were governed by it, and the fee scale is the reference point for what a Tribunal appeal costs. Section 112(10) separately requires every application for rectification of error, for any other purpose, or for restoration of an appeal or application, to be accompanied by the prescribed fees.

The Registrar

Explanation 2 to Rule 111, applying to Rules 110 and 111: "Registrar" shall mean a Registrar appointed by the Government for this purpose, and shall include Joint Registrar, Deputy Registrar and Assistant Registrar.

The Registrar is the filing and record authority — acknowledgements, defects, and the appeal number. Correspondence about a defective filing goes to that office, and the inclusive definition means a communication from a Joint, Deputy or Assistant Registrar carries the same authority.

A filing checklist for the Tribunal

1. Compute the limitation — three months from communication or the notified date, whichever is later under s.112(1). Section 112 →
2. Pay the pre-deposit — the admitted amount in full plus 10% of the remaining disputed tax in addition to the s.107(6) payment, capped at ₹20 crore; and for a penalty-only order, 10% of the penalty in addition to the s.107(6) proviso amount.
3. Check the Bench — any place-of-supply issue sends the appeal to the Principal Bench. Section 109 →
4. File APL-05 electronically, with the documents.
5. Obtain Part A of APL-02A immediately.
6. Submit the self-attested copy at once where the order is off-portal.
7. Clear defects promptly.
8. Obtain Part B of APL-02A with the appeal number — the appeal is filed only then.
9. Diarise the cross-objection window if you are the respondent — forty-five days from notice under s.112(5).

Key takeaways

• Notification No. 13/2025-CT made Tribunal filing electronic from 22.09.2025 and omitted the manual-filing provisos.
• APL-05 for the appeal, APL-06 for cross-objections, both electronically.
• APL-02A replaced APL-02: Part A provisional, Part B final.
• Where the order is not on the portal, the date of the self-attested copy is the date of filing.
• Explanation 1: the appeal is filed only when Part B with the appeal number is issued.
• "Registrar" includes Joint, Deputy and Assistant Registrar.

Read next

• Section 112: Appeal to the GSTAT and the Second Pre-Deposit
• Section 109: GSTAT Benches, and What Only Delhi Can Hear
• Section 112(5): The Memorandum of Cross-Objections
• Notification 13/2025: GSTAT Rules, E-Filing and APL-02A

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition) and Notification No. 13/2025-CT dated 17 September 2025.