The long-awaited Goods and Services Tax Appellate Tribunal (GSTAT) has finally been operationalized — marking a critical milestone in the evolution of India’s indirect tax regime. Designed as the final fact-finding authority under GST, the Tribunal bridges the gap between the administrative machinery and the judiciary. It aims to deliver consistency, transparency, and timely justice in indirect tax litigation — a much-needed step given the large volume of unresolved appeals across the country.
Legal Framework and Formation
The legal foundation of GSTAT lies in Section 109 of the CGST Act, 2017, which provides for the establishment of a Principal Bench at New Delhi and multiple State Benches across India.
While the law existed since 2017, the Tribunal’s constitution was delayed due to constitutional challenges regarding judicial independence. The situation was finally resolved through amendments introduced in the Finance Act, 2023, followed by the issuance of GSTAT Procedure Rules, 2025, which set out detailed guidelines for filing, hearing, and disposal of appeals.
Structure and Jurisdiction
| Attribute | Principal Bench | State Benches |
| Location | New Delhi | 31 State/UT Benches (including Circuit Benches) |
| Composition | 1 President (Judicial) + 1 Judicial Member + 1 Technical Member (Centre) + 1 Technical Member (State) | 2 Judicial Members (senior-most as Vice President) + 1 Technical Member (Centre) + 1 Technical Member (State) |
| Jurisdiction | Disputes on place of supply, anti-profiteering, and other notified matters | All other appeals under GST except those reserved for the Principal Bench |
Filing of Appeals: Staggered Schedule Announced
To ensure smooth operational rollout, the Government has introduced a staggered filing schedule for pending appeals before GSTAT. Businesses must carefully note the applicable window based on when their original order was issued.
| # | Date of filing Appeal (APL-01 / APL-03) OR issue of notice (RVN-01) | Period allowed for filing appeal before GSTAT |
| 1 | on or before 31.01.2022 | 24.09.2025 – 31.10.2025 |
| 2 | Between 01.02.2022 – 28.02.2023 | 01.11.2025 – 30.11.2025 |
| 3 | Between 01.03.2023 – 31.01.2024 | 01.12.2025 – 31.12.2025 |
| 4 | Between 01.02.2024 – 31.05.2024 | 01.01.2026 – 31.01.2026 |
| 5 | Between 01.06.2024 – 31.03.2026 | From 01.02.2026 onwards |
| 6 | Order issued before 31.03.2026 (cases not covered above) | From 01.03.2026 onwards |
| 7 | Where APL-01/03 or notices in RVN-01 not available in GST portal. | From 31.12.2025 onwards |
| 8 | Order in APL-04 communicated after 31.03.2026 | within 3 months of date of communication of APL-04 |
Note: All such appeals must be filed no later than 30 June 2026. For orders issued after 31 March 2026, the regular time limit of three months from the date of order will apply.
Key Highlights from GSTAT (Procedure) Rules, 2025
- Online Filing: All appeals to be filed electronically on the GSTAT portal in prescribed form.
- Pre-Deposit Requirement: 10% of the disputed tax amount (subject to maximum limits).
- Modes of Hearing: Physical, virtual, or hybrid hearings permitted.
- Timely Disposal: Orders to be pronounced within 30 working days from the final hearing.
- Procedural Flexibility: Tribunal may relax procedural requirements to meet ends of justice.
Preparing for GSTAT: Staying Ready
With more than 4.8 lakh pending cases likely to move to the Tribunal, this phase will be crucial for businesses to stay proactive and prepared. Some practical steps include:
- Review all pending litigations: Identify cases eligible for appeal before GSTAT.
- Organize documentation: Maintain clear, indexed sets of appeal papers, orders, and supporting evidence.
- Assess merit and strategy: Evaluate grounds of appeal, factual strength, and the viability of the case.
- Track filing windows: Set internal reminders to ensure timely submission as per the staggered schedule.
- Prepare for digital transition: Familiarize with the GSTAT online portal and procedural filing formats.
How We Can Assist
Our firm is equipped to assist businesses in navigating this new appellate mechanism with a structured approach covering:
- Case review and eligibility assessment for filing before GSTAT
- Drafting and filing of appeals through the online portal
- Advisory on pre-deposit and procedural compliance
- Preparation of factual and legal submissions for hearings
- Representation and litigation support in coordination with legal counsels
With the Tribunal expected to commence hearings from December 2025, now is the time for businesses to organize their litigation portfolios and prepare for a seamless transition into the GSTAT framework.
Author’s note:
The operationalization of the GST Appellate Tribunal marks a major advancement in India’s indirect tax adjudication system. It promises not only faster resolution of disputes but also a more uniform interpretation of GST laws across States and Union Territories.
For businesses, it’s time to shift from waiting to acting—filing strategically, preparing meticulously, and leveraging this new forum to achieve fair and efficient tax justice.
Disclaimer: This blog is intended to provide a brief idea on GSTAT Procedural rules and Appeal filing deadlines. For specific litigation matter or due date, separate consultation required.