GSTAT Revokes Staggered Filing of Appeals Under Section 112 of CGST Act

Last updated: 24 December 2025


The Goods and Services Tax Appellate Tribunal (GSTAT) has revoked its earlier directive mandating staggered filing of appeals under Section 112 of the Central Goods and Services Tax (CGST) Act, 2017. The move is expected to streamline and simplify the GST appeal filing process across the country.

The decision was announced through Order No. 315/2025, issued on December 16, 2025, by GSTAT President Justice Sanjaya Kumar Mishra. The order withdraws the earlier instruction dated September 24, 2025, which required appeals arising from appellate and revisional authority orders under Sections 107 and 108 of the CGST Act to be filed in a phased or staggered manner.

GSTAT Revokes Staggered Filing of Appeals Under Section 112 of CGST Act

According to the tribunal, a fresh assessment of the GSTAT appeal portal's operational capabilities revealed that the system is now equipped to handle appeal filings without restrictions. "In consideration of the current assessment of the portal's capabilities, it is deemed appropriate to dispense with the staggered filing protocol to promote unhindered access while preserving system efficacy," the order stated.

The revocation will take effect from December 18, 2025. However, the GSTAT clarified that appeals already filed under the earlier staggered filing order before this date will remain valid and unaffected. The order further emphasised that the revocation does not dilute or interfere with the statutory powers of the Appellate Tribunal under Section 112 of the CGST Act, 2017.

The earlier directive had been issued under Rule 123 of the GST Appellate Tribunal (Procedure) Rules, 2025, citing system capacity concerns during the initial phase of GSTAT operations. With the withdrawal of this restriction, taxpayers and tax practitioners can now file appeals without timing limitations, ensuring easier access to justice and faster dispute resolution.

Experts believe the move will improve compliance, reduce procedural bottlenecks, and encourage timely filing of GST appeals nationwide.

Official copy of the order has been attached 


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