Appeals & Advance Rulings

Appeal to the Appellate Tribunal

Rule 110 of the CGST Rules

Chapter 13 – Appeals and Revision Text as on 2026-09-05 Source CBIC

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An appeal to the Appellate Tribunal is filed in APL-05 electronically within three months of the order, with the pre-deposit of ten per cent of the remaining disputed tax capped at twenty crore rupees; the acknowledgement is issued in APL-02 and a certified copy filed where required.

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(1) An appeal to the Appellate Tribunal under sub-section (1) of section 112 shall be filed in FORM GST APL-05, along with the relevant documents, electronically and provisional acknowledgement 7 [ in Part A of FORM GST APL-…
(2) A memorandum of cross-objections to the Appellate Tribunal under sub-section (5) of section 112, if any, shall be filed electronically in FORM GST APL-06: Provided that the memorandum of cross-objections may be filed man…
(3) The appeal and the memorandum of cross objections shall be signed in the manner specified in rule 26.
(4) Where the order appealed against is uploaded on the common portal, a final acknowledgement, indicating appeal number, shall be issued 10 [in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of issu…
(5) of section 112, if any, shall be filed electronically in FORM GST APL-06: Provided that the memorandum of cross-objections may be filed manually in FORM GST APL-06, only if the Registrar allows the same by issuing a spec…
(6) There shall be no fee for application made before the Appellate Tribunal for rectification of errors referred to in sub-section (10) of section 112. ]

The exact words of the law

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Reproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.

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Rule 110 1 [Rule 110. Appeal to the Appellate Tribunal.-

(1) An appeal to the Appellate Tribunal under sub-section

(1) of section 112 shall be filed in FORM GST APL-05, along with the relevant documents, electronically and provisional acknowledgement 7 [ in Part A of FORM GST APL-02A ] shall be issued tothe appellant immediately: 8 [****]

(2) A memorandum of cross-objections to the Appellate Tribunal under sub-section

(5) of section 112, if any, shall be filed electronically in FORM GST APL-06: Provided that the memorandum of cross-objections may be filed manually in FORM GST APL-06, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order.

(3) The appeal and the memorandum of cross objections shall be signed in the manner specified in rule 26.

(4) Where the order appealed against is uploaded on the common portal, a final acknowledgement, indicating appeal number, shall be issued 10 [in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of issue of the provisional acknowledgement shall be considered as the date of filing of appeal under sub-rule (1): Provided that where the order appealed against is not uploaded on the common portal, the appellant shall submit or upload, as the case may be, a self-certified copy of the said order within a period of seven days from the date of filing of FORM GST APL-05 and a final acknowledgement, indicating appeal number, shall be issued 10 [in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of issue of the provisional acknowledgment shall be considered as the date of filing of appeal: Provided further that where the said self-certified copy of the order is submitted or uploaded after a period of seven days from the date of filing of FORM GST APL-05, a final acknowledgement, indicating appeal number, shall be issued 10 [in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of submission or uploading of such self-certified copy shall be considered as the date of filing of appeal. Explanation .—For the purposes of this rule, the appeal shall be treated as filed only when the final acknowledgement, indicating the appeal number, is issued.

(5) The fees for filing of appeal or restoration of appeal shall be one thousand rupees 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 twenty five thousand rupees and a minimum of five thousand rupees: Provided that the fees for filing of an appeal in respect of an order not involving any demand of tax, interest, fine, fee or penalty shall be five thousand rupees.

(6) There shall be no fee for application made before the Appellate Tribunal for rectification of errors referred to in sub-section

(10) of section 112. ]

What changed, and when

The amendment trail, newest first — because the version that applies to your case depends on the period.

2025-09-22 · Inserted

13/2025-CTdated

Inserted (w.e.f. 22.09.2025) by Notification No. 13/2025 – CT dated 17.09.2025.

2025-09-22 · Omitted

13/2025-CTdated

Omitted (w.e.f. 22.09.2025) "Provided that an appeal to the Appellate Tribunal may be filed manually in FORM GST APL-05, along with the relevant documents, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as speci

2025-09-22 · Omitted

13/2025-CTdated

Omitted (w.e.f. 22.09.2025) "Provided that the memorandum of cross-objections may be filed manually in FORM GST APL-06, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order." by Notifica

2025-09-22 · Substituted

13/2025-CTdated

Substituted (w.e.f. 22.09.2025) by Notification No. 13/2025 – CT dated 17.09.2025.

2024-07-10 · Substituted

12/2024-CTdated10

Substituted vide Notification No. 12/2024-CT dated 10.07.2024. for "Rule 110. Appeal to the Appellate Tribunal.- (1) An appeal to the Appellate Tribunal under subsection (1) of section 112 shall be filed along with the relevant documents either electronically or otherwise as may be notified by the R

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Where this comes from

Text reproduced from the Central Board of Indirect Taxes and Customs, as available on 2026-09-05. The explanation and practice notes above are GSTZone’s own, written for this hub. If you spot anything out of date, tell us and we’ll fix it — this hub is checked daily against CBIC.

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