GSTAT Cuttack Bench: no further pre deposit can be insisted upon for filing an appeal before the GSTAT under Section 112

The GST Appellate Tribunal, Cuttack Bench, in Manoranjan Dash v. Commissioner, Odisha Commissionerate of CT & GST & Ors. (Order dated 08.07.2026), has held that where the First Appellate Authority has substantially reduced the tax demand, and the pre deposit already made under Section 107 exceeds the amount statutorily required with reference to the reduced demand, no further pre deposit can be insisted upon for filing an appeal before the GSTAT under Section 112.

The Tribunal relied upon the recent judgment of the Jharkhand High Court in Ashirwad Food Industries and observed that the pre deposit requirement under Section 112 stands satisfied if the amount already deposited during the first appellate stage adequately covers the statutory requirement computed on the surviving disputed tax.

This order will be of considerable relevance in cases where the demand has been significantly reduced in first appeal, but the Registry nevertheless insists upon an additional 10% pre deposit at the Tribunal stage.