GST Appeals and Disputes

What this case type involves

Key legal provisions

Provisions are quoted by section and Act. The notes paraphrase their effect; always read the current text of the statute before relying on it.

• ‘Section 73, Central Goods and Services Tax Act 2017’

  determination of tax not paid or short paid for reasons other than fraud.

• ‘Section 74, Central Goods and Services Tax Act 2017’

  determination of tax in cases of fraud, wilful misstatement or suppression.

• ‘Section 107, Central Goods and Services Tax Act 2017’

  first appeal; pre-deposit of admitted tax plus 10 per cent of disputed tax (capped).

• ‘Section 29, Central Goods and Services Tax Act 2017’ and ‘Section 30, Central Goods and Services Tax Act 2017’

  cancellation of registration and revocation of cancellation within 90 days.

Filing procedure, step by step

1. 1Reply to the show-cause notice (DRC-01) with reconciliation and documents; attend the personal hearing.
2. 2File Form GST APL-01 within three months of the order with pre-deposit.
3. 3Appeal to the GST Appellate Tribunal within three months of the appellate order; thereafter the High Court and Supreme Court.

Limitation periods

• First appeal: three months plus one month condonable.
• Revocation of cancelled registration: 90 days from the cancellation order (Section 30, as amended).

Limitation is computed under the Limitation Act 1963 and the specific statute; the time taken to obtain certified copies is generally excluded. Verify the applicable period with counsel before filing.

Documents you will need

• Show-cause notice and reply
• Adjudication order (DRC-07)
• GSTR-1, GSTR-3B, GSTR-2A/2B and reconciliation
• Invoices, e-way bills, bank statements

Practical tips for litigants

• Keep GSTR-2B reconciliations current — most ITC disputes are documentary.
• A personal hearing is mandatory before an adverse order; its denial is a strong ground of appeal.