Topic guide · 49 provisions

Appeals & Advance Rulings

Fighting an order, or avoiding one in advance

Fighting an order, or avoiding one in advance.

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An appeal against an adjudication order goes to the Appellate Authority in Form APL-01, within three months of the order being communicated. A further month can be condoned for good reason – and not a day beyond that, which courts have confirmed repeatedly.

The pre-deposit is 10% of the disputed tax, capped at ₹20 crore, and it is calculated on tax alone – not interest, not penalty. Paying it stays recovery of the balance while the appeal runs. A second appeal to the Tribunal needs a further 10%.

If you would rather not find out the hard way, an advance ruling lets you ask the question before you act. It binds you and the department for your own transaction – useful precisely where classification or valuation is genuinely uncertain.

Pre-deposit is on disputed tax only. Interest and penalty are excluded from the calculation.

Worked example

Working out what an appeal actually costs to start

Demand raised	Tax ₹20,00,000 + interest ₹7,00,000 + penalty ₹2,00,000	Total ₹29,00,000
Pre-deposit is 10% of tax only	₹2,00,000	Not 10% of ₹29,00,000
Recovery of the balance	Stayed while the appeal is pending	₹27,00,000 not payable now

₹2 lakh, not ₹2.9 lakh – and it can be paid from the credit ledger. Businesses routinely overestimate this and abandon appeals they would have won.

The mistakes that cost people money

Not theoretical risks — the ones we actually see land on clients’ desks.

Calculating the pre-deposit on the whole demand. It is 10% of the disputed tax component only.

Filing a rectification request and assuming it pauses the appeal clock. It does not – file the appeal in time as well.

Skipping an advance ruling on a genuinely novel structure, then discovering the department’s view three years and one audit later.

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Common questions on this

Straight answers to what people actually ask us.

How to Appeal Against a GST Order

A GST appeal starts with Form APL-01 to the Appellate Authority, and can escalate through the Tribunal, High C…

How Much Deposit Is Needed to File a GST Appeal?

10% of disputed tax for the first appeal, another 10% for the Tribunal — both capped at ₹20 crore each under t…

What Is the Time Limit to File a GST Appeal?

A first GST appeal must be filed within 3 months of the order, with only 1 further month condonable — after th…

Every provision on appeals & advance rulings

All 49 of them, each with a plain-language explanation and the full legal text.

CGST Act, 2017 · 30

Section 95 Definitions of Advance Ruling Section 96 Authority for advance ruling Section 97 Application for advance ruling Section 98 Procedure on receipt of application Section 99 Appellate Authority for Advance Ruling Section 100 Appeal to Appellate Authority Section 101 Orders of Appellate Authority Section 101A Constitution of National Appellate Authority for Advance Ruling Section 101B Appeal to National Appellate Authority Section 101C Order of National Appellate Authority Section 102 Rectification of advance ruling Section 103 Applicability of advance ruling Section 104 Advance ruling to be void in certain circumstances Section 105 Powers of Authority and Appellate Authority Section 106 Procedure of Authority and Appellate Authority Section 107 Appeals to Appellate Authority Section 108 Powers of Revisional Authority Section 109 Constitution of Appellate Tribunal and Benches thereof Section 110 President and Members of Appellate Tribunal, their qualification, appointment, conditions of service, etc Section 111 Procedure before Appellate Tribunal Section 112 Appeals to Appellate Tribunal Section 113 Orders of Appellate Tribunal Section 114 Financial and administrative powers of President Section 115 Interest on refund of amount paid for admission of appeal Section 116 Appearance by authorised representative Section 117 Appeal to High Court Section 118 Appeal to Supreme Court Section 119 Sums due to be paid notwithstanding appeal, etc Section 120 Appeal not to be filed in certain cases Section 121 Non-appealable decisions and orders

CGST Rules, 2017 · 19

Rule 103 Qualification and appointment of members of the Authority for Advance Ruling Rule 104 Form and manner of application to the Authority for Advance Ruling Rule 105 Certification of copies of advance rulings pronounced by the Authority Rule 106 Form and manner of appeal to the Appellate Authority for Advance Ruling Rule 107 Certification of copies of the advance rulings pronounced by the Appellate Authority Rule 107A Manual filing and processing Rule 108 Appeal to the Appellate Authority Rule 109 Application to the Appellate Authority Rule 109A Appointment of Appellate Authority Rule 109B Notice to person and order of revisional authority in case of revision Rule 109C Withdrawal of Appeal Rule 110 Appeal to the Appellate Tribunal Rule 111 Application to the Appellate Tribunal Rule 112 Production of additional evidence before the Appellate Authority or the Appellate Tribunal Rule 113 Order of Appellate Authority or Appellate Tribunal Rule 113A Withdrawal of Appeal or Application filed before the Appellate Tribunal Rule 114 Appeal to the High Court Rule 115 Demand confirmed by the Court Rule 116 Disqualification for misconduct of an authorised representative

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