Step by step guide to GSTAT and issues faced in uploading the Appeal

Concept of Tribunal

A Tribunal is a quasi-judicial body constituted to adjudicate disputes within a specialised domain. Unlike conventional courts, tribunals are designed to combine judicial independence with subject-matter expertise. Under the GST regime, the Goods and Services Tax Appellate Tribunal (GSTAT) assumes critical importance as the final fact-finding authority before a matter reaches the jurisdictional High Court.

The legislative intent behind the constitution of GSTAT is rooted in the need for uniformity, consistency, and technical precision in the adjudication of indirect tax disputes across the country. As articulated in the Government Press Release dated 24th September 2025, GSTAT is envisaged as a specialised, technology-driven appellate forum aimed at enhancing predictability in tax jurisprudence and strengthening institutional trust between taxpayers and tax administration.

The structural framework of GSTAT reflects three foundational pillars — Structure, Scale and Synergy:

1. Structure – A balanced composition of Judicial Members and Technical Members (Centre and State) ensures that legal interpretation is harmonised with practical tax administration experience.
2. Scale – Establishment of Principal Bench and State Benches, along with provision for Single-Member Benches in specified matters, enhances accessibility and reduces geographical barriers to justice.
3. Synergy – Integration of digital infrastructure, e-filing mechanisms, case management systems, and virtual hearing facilities promotes procedural efficiency, transparency, and time-bound disposal of appeals.

Thus, GSTAT is not merely an appellate forum but an institutional mechanism intended to standardise GST interpretation nationwide and reduce the burden on constitutional courts. Its effective functioning is essential for stabilising GST jurisprudence and ensuring certainty in tax administration.

Part I Step by Step Guide to GSTAT

• Who can file Appeal in GSTAT?

Taxpayer, Tax Official, Authorised person, Advocate, Legal Representative.

Currently, as Taxpayer Appeal of GSTAT has be filled and Before that Authorised person/ Advocate/ Legal Representative of the Tax Payer must themselves Register themselves on GSTAT Portal.

• How to File Appeal of GSTAT?

Separate website https://efiling.gstat.gov.in launched on 24th Sept, 2025 for filling Appeal of GSTAT. GSTAT e-Courts Portal unveiled to enable taxpayers and practitioners to file appeals online, track the progress of cases, and participate in hearings through digital mode.IT developed a digital platform that will anchor the work of GSTAT from the very start. e-Filing, case management tools, and electronic court modules will make proceedings smoother and more transparent, setting new benchmarks for the functioning of a Tribunal in our country.

• Complete Procedure with Practical Aspects
  • Process of Filling Appeal to GST Appellate Tribunal
    • Snapshot for the entire appeal filing process
      • Step 1 : Getting Started on the Homepage- https://efiling.gstat.gov.in/mainPage.drt
      • Step 1.1 Download the Offline Draft Filing Excel Sheet (Strongly Recommended)
      • Step 1.2: Select your Role on the first page (Mandatory): Choose from dropdown viz. “Taxpayer”/ “Tax Officers”/“Authorized Representative”
      • Section 2: The E-Filing and Submission Process
      • Step 2.1: Login and Initial Setup
      • Step 2.2: Completing the Appeal Form
        • Order details
        • Basic s Case Details
        • Appellant s Respondent Details
        • Add Representative
        • Demand Details
        • Upload Documents
        • Checklist s Final Preview
      • Step 2.3: Appeal Fee Payment
      • Step 2.4: Digital Signing and Final Submission

Note:- Toll-Free Number: 1800-103-4782, if any query is there and one can report an issue by filling incident report on GSTAT Portal. 

• Necessary Documents Required at the time of Filling
  • Appeal
  • Affidavits
  • Annexure
  • Impugned Order
  • Vakalatnama
  • Payment Receipt
  • Any Other Document
  • Higher Court Order or Self Calculation Sheet
  • Condonation Of Delay
  • Show-Cause-Notice

All the Documents can be signed via External DSC Utility, NIC DSC Utility, Aadhar based Utility

• Complete Check List for GSTAT
  • Has the order appealed against (i.e., the order of the Appellate/Revisional authority) been uploaded with a self – certified copy?
  • Has the order passed by the proper officer (i.e., the order against which the appeal before the appellate authority was preferred under section 107/the order that has been revised under section 108) been uploaded with a self – certified copy?
  • Have the issues under dispute before the Tribunal been clearly stated in the present appeal?
  • Has a case summary of the dispute before the Tribunal been provided in the present appeal?
  • Has a statement of facts regarding the dispute before the tribunal been included in the present appeal?
  • Have all uploaded documents been digitally signed by the person uploading them?
  • Have the fees as specified in rule 110(5) of the CGST Rules, 2017, been paid?
  • Has bookmarking/pagination been done according to the index?
  • Have all documents uploaded been colour scanned from the respective originals?
  • Has the appeal been prepared in English?
  • If any orders/notices/statements were passed in a language other than English, has an English translation been uploaded?
  • Are all affidavits properly attested and identified?
  • If an English translation has been uploaded, has an affidavit confirming the accuracy of the translation been uploaded by the appellant/authorized representative/translator?
  • Have the details of the appellate/revisional authority(designation and office) been correctly and fully specified in the present appeal?
  • Have any notices issued by the appellate/revisional authority been uploaded with a self-certified copy?
  • Have any shows cause notices/statements issued by the proper officer (the authority referred to in the point 3) been uploaded with a self-certified copy?
  • Have the details of the officer/authority (as referred to question no. 3) who passed the order (designation and office) been correctly and specified filled in the present appeal?
  • Has the order (of the order referred to in the previous question) been correctly and specified filled in the present appeal?
  • Has the required amount of pre-deposit as per section 112(8) of the CGST Act, 2017, been made?
  • Have all documents been uploaded with correct indexing in a single PDF?
  • Have all the documents requiring the signature of the parties been physically signed, scanned, and uploaded?
  • Have all type-written documents uploaded with the present appeal, been typewritten on one side of A4 size paper with double spacing, justified horizontal alignment in the specified font and font size?
  • Are all documents/enclosures are fully and properly scanned in A4 colour with the specified DPI resolution, with no pages missing?
  • If Paper Books are included, are they properly paginated and indexed?
  • All documents/ enclosures are fully and properly scanned in A4 colour with the specified DPI resolution and that no pages are missing
  • Has present appeal been filled under the correct ‘Category of case’ and has the appropriate code been specified therein
  • Whether the amount of demand as per the present appeal is in accordance with the order passed by the appellate authority under section 107
  • Whether the amount admitted before the appellate authority under section 107 as declared in the present appeal is in accordance with the appeal filed before the said authority
  • Any other

Part II Issues faced in uploading the appeal on GSTAT Portal

• Some basic issues of limitation Period

First Appeal which is filled beyond a limitation period prescribed Section 107(4) i.e. beyond 4 months/ 120 days in such case First Appellate authority rejects the Appeal and they do not the Appeal so such Appeals filled which are beyond limitation period will be heard in GSTAT or not? This issue is a nationwide issue as beyond 4 months Delay cannot be condone by the Commissioner of Appeal of GST.

• Filling fees

Rule 110(5) prescribes for Appeal filling fees ofRs. 1,000 for every one lakh rupees of tax or input tax credit involved or the difference in tax or input tax credit involved or the amount of fine, fee or penalty determined in the order appealed against, subject to a maximum of Rs. 25,000 and a minimum of Rs. 5,000.

On GSTAT Portal, under the “Court Fees” tab which is having two options Online payment through Net banking/ Debit Card/ Credit Card and BharatKosh Offline.

While payment the User faces payment gateway failures for example payment is debited but not reflected on GSTAT Portal, or transaction got stuck in “Pending” or “Failed” status.

• Filing Procedure issues

GSTAT Portal issues are being faced by the tax professionals in the course of filling appeals before the Hon’ble GST Tribunal.

• • Lack of information on GSTAT portal does not provide details of Number of benches of GSTAT and their respective address, if this information is updated on portal of GSTAT itself will enhance transparency, accessibility and administrative convenience.
  • Data issues in Synchronization such as Auto population failures of previous appeal orders (APL-04), ARN/CRN not found issue of the first appeal, particularly for older or manual cases due to non-availability on GSTAT Portal.
  • GSTAT portal is separate so it creates more compliance burden and taxpayer has to manage two separate portal. 
  • Many Registered users are facing issues in LOGIN and Forgot Password such technical issues are preventing in filling of Appeal in GSTAT Portal.
  • Loop glitches found on GSTAT Portal because after login portal send back to Appeal Reference Number (ARN) page after login which prevents them from to proceed towards filling forms and other documents.
  • Redirect issued found on GSTAT Portal, often, the portal is directing the users to the login pages without displaying error messages. If such bug is removed the GSTAT portal will be hassle free for navigation 
  • Failure in uploading documents faced by users while uploading documents requires exhibits, annexures, or other documents.
  • Low website performance due to slowdown, page timeouts and non-functioning of buttons in heavy traffic hours which causes difficulty in appeal filling over GSTAT Portal.
  • Payment gateway failure in Bharatkosh found whether payment is debited but not reflected or transactions get stuck in “Pending” or “Failed” status on GSTAT Portal.
  • Problem in navigation which Is faced by user which restricts access to “Upload Documents” or “Final Preview” tabs until payment details are fully updated on portal.
  • File size limitations on document sizes e.g. max 20 MB per file cause issues in filling of bulky appeals.
  • Confusion and Difficulty in Certification of Documents though relaxation announced for the initial months
  • Non-Updating of Registered Contact Information on GSTAT Portal as result the OTP goes to former registered Authorised Signatory of a Taxpayer who has been discharged from his duties although on GST portal Authorised person contact details are already changed.
  • Due to Inactive filling slots portal of GSTAT may show “Slot Inactive” message if the user tries to file outside their designated, staggered schedule window issued by Order dated 24-09-2025.

PART III Issues come up while Filling Appeal of GSTAT and Solution

• In order what to select appeal order or original order?

Solution – There is no such option over portal. On GSTAT Portal, In order details there are two options “ARN/CRN Available” and “ARN/CRN not Available”. So, here ARN of Appeal order or Original Order should be selected and it will be reflecting over GSTAT Portal.

• Who’s should be respondent?

Solution – Respondent will be concerned Jurisdictional Commissioner. Rule 33 of Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 Notification No. G.S.R. 256(E). dated 24th April, 2025 issued by Ministry of Finance.

• If appeal is against order of First Appellate Authority (FAA)

Response -As per Rule 33, the Commissioner concerned shall be made therespondent to the appeal or the application, as the case may be. So, the Respondent will be the Concerned Commissioner of CGST/SGST having Jurisdictionof the Assessee/ Tax Payer.

• If Department/ Any Commissioner files appeal before GSTAT

Response -As per Rule 33, the other party shall be made therespondent to the appeal. So, Respondent will be the Assessee/ Taxpayer

• Where is the office? Whether this information available? Who is the concerned bench? Whether this information available?

Solution – On GSTAT website, information of Benches Statewise and their address is not available. Even, Statewise bench Location of city is declared by virtue of Notification S.O. 4073(E). New Delhi, the 14th September, 2023 but that is not available over GSTAT Portal and Adress of State Bench not declared by Notification. So, in absence of this information of concerned bench and their address, Filling of GSTAT Appeal not possible.  

• When order is passed manually then what?

Solution –When order is passed manually “ARN/CRN not Available” option has to be selected in Order type while filling Appeal Online on GSTAT Portal.

• When appeal cannot be filed online then what?

Solution –All Appeals must be filled online as per GSTAT Rules and when ARN/CRN of Appeal Not available, one can select “ARN/CRN not Available” option in Order type while filling Appeal Online.

• Where and when to submit physical papers after filling Appeal Electronically on GSTAT Portal?

Solution – Rule 110(4) provides that when Appeal is filled electronically of Order available having ARN/CRN details,shall be filed in FORM GST APL-05, along with the relevant documents, electronically and provisional acknowledgement in Part A of FORM GST APL-02A shall be issued tothe appellant immediately in such situation there is no need to file physical papers to concerned bench physically.

In absence of the availability of the first appeal order or revision order on the portal,i.e. ARN/CRN not available, the Appellant required to submit a self-certified copy of the order appealed against within 7 days of manual filing of appeal.

• Who has to sign it?

Solution – At the foot of every appeal or pleading along with allthe relevant documents including relied upon documents, there shall appear the name and signature of the authorised representative and every appeal or pleadings shall be signed and verified by the party concerned in the manner provided by these rules.

Rule 22 Endorsement and verification prescribe signing procedureGoods andServices Tax Appellate Tribunal (Procedure) Rules, 2025 Notification No. G.S.R. 256(E). dated 24th April, 2025 issued by Ministry of Finance.

Concluding Remarks

The introduction of the GSTAT portal is a welcome advancement in India’s GST dispute resolution framework. As the final fact-finding authority, GSTAT is expected to bring consistency and certainty to GST litigation. However, practical challenges such as technical glitches, payment failures, limitation concerns, and data synchronisation gaps have affected smooth access to the portal, resulting in comparatively low e-filing of appeals.

Addressing these implementation issues and ensuring fully functional Benches will be essential to achieve the objective of speedy and uniform adjudication. With timely refinements and systemic stability, GSTAT can meaningfully strengthen the appellate architecture under the GST regime.