Representation seeking extension of the last date for filing appeals before GSTAT by STBA

Sales Tax Bar Association (Regd.) (STBA) made representation for extension of the time limit for filing appeals before the Goods and Services Tax Appellate Tribunal (GSTAT) vide letter reference STBA/2026/25 dated 25.06.2026

Subject: Representation seeking extension of the time limit for filing appeals before the Goods and Services Tax Appellate Tribunal (GSTAT) beyond 30.06.2026 on account of persistent technical and practical difficulties in the GSTAT e-filing portal.

Hon’ble Madam,

1. Sales Tax Bar Association (Regd.), having been established on 30th March, 1957, is one of the oldest and the largest Association of Tax Professionals in the country. The Bar represents majority of members of various professions practicing in the Direct & Indirect Taxes. Sales Tax Bar Association (Regd.) plays a major role in revenue collection by the department. Present membership of our Bar Association is around 2000 comprising of Advocates, CA’s and Tax Practitioners. Some of our members were elevated as Judges of the Hon’ble Delhi High Court and elevated as Judges of the Hon’ble Supreme Court. Some of our members further were also selected for appointment as Member of the Income Tax Appellate Tribunal (ITAT) and Goods & Services Tax Appellate Tribunal (GSTAT).
2. However, despite the commencement of the Tribunal and the introduction of the online filing mechanism, taxpayers and tax professionals across the country continue to face substantial practical and technical challenges in filing appeals through the GSTAT portal. These difficulties are neither isolated nor individual in nature. Our Association has received numerous grievances from Professionals practicing across different State highlighting recurring issues that have significantly affected the ability of taxpayers to file appeals within the prescribed period.
3. It is respectfully submitted that the Government has already been very sensitive to the problems faced by the taxpayers in filing of the appeals in the GSTAT and accordingly the Government vide Notification No. S.O. 4220 (E) dated 17.09.2025 had issued a notification by exercising its power under Section 112 (1) of the CGST Act, 2017. That vide the said Notification the Government had notified the due date for filing of appeal before the Appellate Tribunal as 30th June, 2026 in respect of all cases, where the order sought to be appealed against was passed on or before 01st April, 2026.
4. It is respectfully submitted that thus the present limitation period pertains to appellate orders accumulated over almost nine years, during which the Tribunal remained non-functional. Preparation of these appeals itself requires considerable effort, including retrieval of old records, compilation of tax demands and preparation of detailed paper books. The recent operationalisation of the GSTAT portal has, therefore, resulted in an unprecedented volume of appeals being required to be prepared and filed within a comparatively shot period.
5. While taxpayers and professionals have made every endeavour to comply with the prescribed timelines, the practical functioning of the portal has substantially reduced the effective period available for filing appeals. Some of the major difficulties experienced across the country are summarised below:
   • Firstly, taxpayers continue to experience frequent portal-related issues including slow response time, session expiry, server interruptions and repeated login failures. In several instances, professionals spend considerable time completing an appeal, uploading documents and entering detailed information, only to find that the session has expired or the portal has hanged and become unresponsive, compelling them to recommence the entire process.
   • Secondly, repeated failures in Aadhaar authentication and Digital Signature Certificate (DSC) validation have caused significant disruption in completing the filing process. Even where taxpayers possess valid Aadhaar credentials and duly registered Digital Signature Certificates, authentication, frequently fails or requires multiple attempts before the appeal can proceed further to the next stage.
   • Thirdly, payment of the mandatory pre-deposit and court fee through the integrated payment gateway has also presented considerable practical difficulties. There have been instances where payments are debited from the taxpayer’s account but the payment status is not immediately reflected on the portal, creating uncertainty regarding successful filing and necessitating further follow-up and reconciliation.
   • Fourthly, the portal presently requires extensive manual entry of information which is already available on the GST common portal. Instead of seamless integration between the GSTN and the GSTAT portal, taxpayers are required to repeatedly enter registration particulars, order details and other information , making the filing process unnecessarily time-consuming and increasing the possibility of inadvertent errors.
   • Fifthly, appeals under the GST regime frequently involve voluminous records comprising show cause notices, replies, adjudication orders, appellate orders, invoices, reconciliations, e-way bills, ledger extracts bank details and other supporting documents accumulated over several years. Preparation of such records in accordance with the portal’s prescribed technical specifications regarding document size, format and uploading requirement has itself become a substantial exercise, particularly for appeals involving complex factual issues.
6. Further, practical issues continue to be experienced in filing appeals relating to certain categories of persons, including matters involving penalties imposed upon directors, partners and other persons who do not have a valid GST registration. In several such cases, the portal does not presently facilities smooth filing of appeals, thereby creating uncertainty regarding the availability of the appellate remedy.
7. It may also be appreciated that the GSTAT is a newly operationlised appellate forum with a completely new electronic filing framework. Taxpayers, advocates, chartered accountants and tax practitioners across the country are simultaneously familiarising themselves with the portal architecture, procedural requirements and filing methodology. A reasonable transition period is, therefore, both necessary and desirable to ensure effective implementation of this important final facts finding appellate forum.
8. The above circumstances demonstrate that the request for extension does not arise on account of any lack of diligence on the part of taxpayers or professionals. On the contrary, taxpayers are making genuine efforts to exercise the statutory remedy available to them but are encountering practical difficulties beyond their control while navigating a newly introduced electronic problem.
9. If the present timeline is not extended, thousands and thousand of genuine taxpayers may lose the opportunity to avail the appellate remedy solely because of technical and procedural difficulties associated with the portal. Such a situation would inevitably lead to avoidable litigation before various High Courts seeing appropriate reliefs in respect of limitation and portal-related issues , thereby increasing the burden upon the judiciary, the Department and the Tribunal itself. This would also run contrary to the Government’s consistent objective of promoting ease of doing business, reducing litigation and facilitating voluntary tax compliance through efficient digital governance.
10. It is respectfully submitted that granting a reasonable extension would not prejudice the interest of the Revenue in any manner. The statutory conditions governing appeals, including the mandatory pre-deposit prescribed under the Act, would continue to remain fully applicable. The extension would merely ensure that genuine taxpayers are afforded a fair and effective opportunity to avail the appellate remedy intended by the Legislature, while simultaneously allowing adequate time for further stabilisation of the GSTAT portal.
11. In these circumstances, we most respectfully request your kind intervention to :
    • Extend the last date for filing appeals before the GST Appellate Tribunal from 30.06.2026 to 30.09.2026 or for such further period as the Government may consider appropriate.
    • Ensure that taxpayers facing genuine portal-related technical difficulties are not deprived of their opportunity to file appeals on account of circumstances beyond their control; and
    • Continue strengthening and stabilising the GSTAT e-filing system during the extended period so that the objective of establishing an efficient, accessible and technology-driven appellate mechanism may be fully realised.

We are confident that your good office, which has consistently demonstrated its commitment towards taxpayer-friendly reforms and fair tax administration, will kindly consider this genuine request sympathetically in the larger interest of justice, efficient tax administration and ease of doing business.

We shall remain grateful for your kind consideration.

Yours faithfully,

[Sanjay Sharma],
President (m) : 9810071545

[Narendra Kr. Sharma],
Secretary (m) : 9811949733

CC to:

1. Hon’ble Minister of State for Finance, Room no. 16042, 6th Floor, A Wing, Kartavya Bhawan -I, New Delhi – 110001.
2. The Revenue Secretary, Ministry of Finance, Govt. of India, Room No. 14102, Kartavya Bhawan – I, New Delhi -110001.
3. The Joint Secretary, GST Council, 5th Floor, Tower II, Jeevan Bharti Building, Connaught Place, New Delhi-110001.
4. The Chairman, CBIC, North Block, Central Secretariat, Room No. 14042, Kartavya Bhawan – I, New Delhi -110001.
5. The President, GSTAT Pr. Bench, 6th Floor, Tower II, Jeevan Bharti Building, Connaught Place, New Delhi-110001.