GST First Appeal u/s 107 (APL-01)

An appeal against an order of the adjudicating authority lies before the Appellate Authority under Section 107, filed online in Form APL-01. In Chhattisgarh, this means the Appellate Authority of the State Tax department or the Commissioner (Appeals) of Central Tax, depending on the authority that passed the order.

GST, Chhattisgarh

Overview

On payment of the admitted tax and a pre-deposit of 10% of the disputed tax (up to ₹20 crore each under CGST and SGST), recovery of the balance demand is stayed while the appeal is pending.

From 1 October 2025, an appeal against an order that demands only penalty, with no tax, needs a pre-deposit of 10% of the penalty (Finance Act, 2025). This includes detention orders under Section 129(3), which needed 25% before that date. The Delhi High Court has held that this 10% does not apply where the show cause notice was issued before 1 October 2025, and the GSTAT has taken the same view for the matching Tribunal pre-deposit.

When this applies

  • Demand orders u/s 73 / 74 / 74A
  • Refund rejection orders
  • Registration cancellation orders
  • E-way bill penalty orders

Time limit

Within three months from the date of communication of the order. A further delay of up to one month can be condoned for sufficient cause.

Documents needed

  • Order (DRC-07) and SCN
  • Reply and evidence filed before the adjudicating authority
  • Proof of pre-deposit

How we handle it

  1. Draft the statement of facts and grounds of appeal
  2. Compute and pay the pre-deposit
  3. File APL-01 with documents and obtain the provisional acknowledgement
  4. Represent at the hearing and file written submissions

Points to note

  • Grounds should cover procedural lapses (no hearing, non-speaking order) as well as merits
  • Check whether a rectification u/s 161 is a faster remedy for obvious errors

What usually comes next

Frequently asked questions

Is pre-deposit refundable?

Yes. If the appeal succeeds, the pre-deposit is refundable with interest as per law.

Can new evidence be filed in appeal?

Additional evidence can be admitted in limited circumstances under Rule 112, with reasons for not producing it earlier.

Official sources

Received a notice or an order?

Call us to talk it through. Keep the notice and its response date handy.

Related services

← All GST Appeals