GST Appeal & Revision
Appeals against GST orders before the Appellate Authority and GSTAT — pre-deposit, drafting, stay of recovery and hearing representation.
- Estimate Cost
- ₹15,000 – ₹1,50,000
- Typical duration
- 30 days
Service overview
- GST Appeal & Revision provides legal representation to challenge adverse orders issued by GST Proper Officers under Sections 107 (Appellate Authority) and 112 (GST Appellate Tribunal - GSTAT)
- This service covers reviewing assessment orders, calculating statutory pre-deposits, drafting appeal memorandums, securing stays on recovery, and representing clients in appellate hearings
Who needs it? / When is it needed?
- Taxpayers served with demand orders under Sections 73, 74, or 74A
- Businesses facing wrongful rejection of Input Tax Credit (ITC), refund claims, or cancellation of GST registration
- Entities seeking revision of orders under Section 108
What to expect from the WCP Professionals
- Deconstruct the Impugned Order: WCP professionals analyze the officer's order to identify legal errors, procedural violations, and factual misinterpretations.
- Evaluate Appeal Merit & Pre-Deposit: WCP professionals calculate the mandatory 10% pre-deposit under Section 107 and give you a clear assessment of your chances before you pay.
- Draft Statement of Facts & Grounds: WCP professionals draft a detailed Appeal Memorandum (Form APL-01) with relevant statutory provisions and case laws.
- File Stay & Secure Recovery Relief: WCP professionals submit proof of pre-deposit (Form APL-02) to automatically stay recovery proceedings on the remaining 90% disputed tax.
- Argue Before Appellate Bench: The advocates represent you during personal hearings, presenting factual evidence and legal precedents.
- Pursue Tribunal Options: If the first appeal is unfavorable, WCP professionals prepare paper-books for further appeal before the GST Appellate Tribunal (GSTAT).
Key deliverables
- Comprehensive Order Analysis & Legal Prospects Report. Drafted Appeal Memorandum (Form APL-01
- APL-05). Pre-deposit Calculation and Payment Challans. Form APL-02 Acknowledgment confirming stay of recovery. Final Appellate Court Order copy with implementation guidance.
Standard turnaround time
- Order Analysis & Strategy: 2 to 4 business days.
- Appeal Preparation & Portal Filing: 5 to 10 business days.
- First Appeal Disposal: 6 to 12 months (subject to court listing).
Government fees, timelines & key outcomes
First appeal (Section 107): the admitted amount plus a pre-deposit of 10% of the disputed tax, capped at ₹20 crore each under CGST and SGST.
GSTAT appeal (Section 112): a further 10% of the disputed tax, capped at ₹20 crore each under CGST and SGST, and a filing fee of ₹1,000 per ₹1 lakh of tax, credit, fine or penalty involved — minimum ₹5,000, maximum ₹25,000.
Time limits: three months from communication of the order for both appeals, with condonation of one month for the first appeal and three months for GSTAT.
Key outcomes: recovery of the balance stayed on payment of the pre-deposit, and the demand reduced or set aside on appeal.
Forms & filings involved
- Form GST APL-01 — first appeal before the Appellate Authority
- Form GST APL-02 — acknowledgement of the appeal
- Form GST APL-05 — appeal before the GST Appellate Tribunal, filed on the GSTAT portal
- Applications for condonation of delay and additional evidence, where required
An appeal to GSTAT is treated as filed only when the final acknowledgement with the appeal number is issued.
Documents required
- Copy of the Impugned Assessment Order and Summary (DRC-07)
- Original Show-Cause Notice (SCN) and replies filed
- Invoices, GSTR-3B/1 returns, ledgers, and bank statements
- Pre-deposit payment challan (DRC-03)
What we need from you
- Complete case files including all notices and past correspondence
- Timely payment of the statutory 10% pre-deposit
- Formal Authorization Letter (Vakalatnama) for legal representation
Important conditions
- Statutory appeal timelines are non-negotiable; missing the condonation window bars appeal rights
- Pre-deposit is a non-waivable legal precondition under the CGST Act
- Professional fees cover legal representation; pre-deposits and court fees are billed at actuals
Additional information
If an order contains obvious mathematical errors, filing a Rectification Application under Section 161 is faster and cheaper than a full appeal.
The estimated cost covers indicative professional fees only. Government fees, stamp duty and taxes are payable at actuals.
How it works
- 1. Raise a service enquiry describing your requirement.
- 2. A Relationship Manager reviews it and opens it for bidding.
- 3. Pay into escrow and assign the professional you select.
- 4. Track progress to completion, then accept and release payment.
Frequently asked questions
How much pre-deposit is needed for a GST appeal?
10% of the disputed tax for the first appeal, and a further 10% for a GSTAT appeal, each capped at ₹20 crore under CGST and SGST, plus the admitted amount.
What is the time limit for a GST appeal?
Three months from the date the order is communicated, extendable by one month for the first appeal and three months for GSTAT on sufficient cause.
Does filing an appeal stop recovery?
Yes. Once the pre-deposit is paid, recovery of the balance is deemed stayed until the appeal is decided.
What is the GSTAT filing fee?
₹1,000 for every ₹1 lakh of tax, credit, fine, fee or penalty involved, subject to a minimum of ₹5,000 and a maximum of ₹25,000.