File a First Appeal explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
To file a GST first appeal, submit Form APL-01 online within three months of the order under Section 107, pay the pre-deposit of the admitted amount plus 10% of the disputed tax (capped at ₹20 crore), file the certified copy within seven days, and receive acknowledgement in APL-02.
Overview
A first appeal is the taxpayer's remedy against any decision or order passed by an adjudicating authority under GST — demand orders, refund rejections, registration cancellations and the like. It is filed before the first appellate authority and is the mandatory step before approaching the GST Appellate Tribunal.
When It Is Required & Legal Basis
The first appeal is governed by Section 107 of the CGST Act, 2017 read with Rule 108 of the CGST Rules. Any person aggrieved by an order under the Act may appeal within three months of communication, extendable by one month for sufficient cause. The mandatory pre-deposit is prescribed under Section 107(6).
Step-by-Step Process
- Compute the pre-deposit. Pay the full admitted tax, interest, fee and penalty, plus 10% of the disputed tax (capped at ₹20 crore under CGST), from the electronic cash/credit ledger as permitted.
- File APL-01 online. Go to Services > User Services > My Applications > Appeal to Appellate Authority and file Form GST APL-01, uploading grounds of appeal and the disputed order.
- Submit the certified copy. File a certified copy of the impugned order within seven days of the electronic filing under Rule 108.
- Receive APL-02. The registry issues a provisional acknowledgement, and a final acknowledgement in Form GST APL-02 with the appeal number once the papers are in order.
- Hearing. The appellate authority grants up to three adjournments, hears the matter, and passes a speaking order confirming, modifying or annulling the demand.
Forms, Attachments & Fees
| Form | Purpose | Timeline |
|---|---|---|
| APL-01 | Taxpayer's first appeal | Within 3 months of order |
| Certified copy | Copy of impugned order | Within 7 days of filing |
| APL-02 | Acknowledgement / appeal number | On acceptance |
| APL-03 | Departmental appeal | Within 6 months of order |
There is no separate filing fee; the effective cost is the 10% pre-deposit plus professional charges for drafting the grounds of appeal.
Timeline & Due Dates
File within three months; a delay of up to one further month can be condoned under Section 107(4) on sufficient cause. The appellate authority is expected, where possible, to decide within one year of filing under Section 107(11).
Penalty for Delay / Non-compliance
A late appeal beyond the condonable window is barred and the original order becomes final and recoverable. Failure to make the 10% pre-deposit renders the appeal defective and it will not be admitted, so recovery of the full demand continues.
Practical Tips
- Pay the pre-deposit before filing and keep the challan/DRC-03 reference ready for APL-01.
- Draft crisp, ground-wise objections tied to sections and facts, not general grievances.
- Do not miss the seven-day certified-copy deadline — its absence delays APL-02.
- Preserve proof of the order's communication date; limitation runs from that date.