GST Basics #25: Section 112 - Appealing to the GST Appellate Tribunal

If your first appeal under Section 107 fails, the next stop is the GST Appellate Tribunal, and its Chennai bench is sitting. What Section 112 involves in practice: Form APL-05, court fees, pre-deposit, defects and timelines.

The last instalment covered the first appeal under Section 107, which goes to a departmental officer. If that appeal fails, the next stop is not a court. It is the GST Appellate Tribunal, and Section 112 is the provision that takes you there. The Tribunal is the first genuinely independent forum in the GST chain, and its Chennai bench has been sitting since April 2026.

The whole thing is electronic. Rule 115 of the GSTAT (Procedure) Rules, 2025 requires every appeal to be uploaded on the GSTAT portal, scrutinised and processed there, with notices and communications issued the same way and the proceedings recorded on the portal. Hearings are ordinarily physical, but may be held electronically with the President's permission. Your form is GST APL-05. If the department is the one appealing it uses APL-07, and if you want to answer its appeal you file cross-objections in APL-06. Other applications go in GSTAT FORM-01.

Three practical points that catch people out. First, one impugned order means one appeal, however many show cause notices, refund claims or demands it disposed of; but where the order covers several original orders, or several persons, each needs its own appeal. Second, a certified copy of the order you are appealing against must accompany the appeal. Third, if the registry finds a defect, you get seven working days from the return to cure it, and the Registrar may extend that but not beyond thirty days from filing. Miss it and the appeal can simply be refused registration.

Money. The Tribunal's own portal puts the court fee at one thousand rupees for every one lakh rupees involved, capped at twenty-five thousand rupees for a demand or enforcement order, and five thousand rupees for other kinds of order. Certified copies cost five rupees a page. The department pays no fee at all. There is also a pre-deposit, which the portal states as twenty per cent of the tax in dispute. Check that figure and how it interacts with the ten per cent you already paid at the first appeal before you pay anything, because Section 112 has been amended and the portal's phrasing is not the section.

Two things in your favour. Documents not in English must be filed with a certified English translation, so keep that in mind for Tamil records. And the Tribunal must pronounce its order within thirty days of the final hearing, which is a discipline the departmental stages do not have.

Read the rules yourself at https://efiling.gstat.gov.in/downloads/manual/Procedure_Rules.pdf and the filing manual at https://efiling.gstat.gov.in/downloads/manual/manual.pdf

See also instalment #22 on the first appeal and #21 on how the demand arose.

Topics:Section 112GST Appellate TribunalGSTATAPL-05GSTAT pre-depositGST appealGSTAT Chennai benchGSTAT Procedure Rules 2025cross-objectionsGST BasicsChennai GSTTamil Nadu GST

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