CBIC issues Circular Clarifying Review, Revision & Appeal Authorities for CAA Orders for SCNs Issued by DGGI [Read Circular]

The Central Board of Indirect Taxes and Customs ( CBIC ) has issued Circular No. 250/07/2025-GST dated 24th June 2025, clarifying the review, revision and appeal procedures for Orders-in-Original (O-I-Os) passed by CAAs on show cause notices ( SCNs ) issued by the Directorate General of GST Intelligence ( DGGI ).

The clarification comes against the backdrop of earlier notifications and circulars, particularly Notification No. 02/2017 and Circular No. 239/33/2024-GST, which designated Joint or Additional Commissioners in specified Commissionerates as CAAs for adjudicating DGGI SCNs.

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However, until now, there was no clear procedural framework for which authorities would handle reviews, revisions, and appeals for such orders, resulting in interpretational issues and operational uncertainty.

The Board, after consulting the Ministry of Law and Justice, has now laid down a clear hierarchy to ensure uniformity. Under Section 107 of the CGST Act, 2017, the Principal Commissioner or Commissioner of Central Tax under whose jurisdiction the CAA is posted shall act as the reviewing authority for such O-I-Os.

Likewise, the same Principal Commissioner or Commissioner will function as the revisional authority under Section 108 for orders passed by CAAs who are Additional or Joint Commissioners.

Further, the appeals against such O-I-Os will lie before the Commissioner (Appeals) corresponding to the territorial jurisdiction of the Principal Commissioner or Commissioner under whom the CAA functions, as per Table III of Notification No. 02/2017-Central Tax dated 19th June 2017. This ensures that appellate jurisdiction aligns with the territorial posting of the CAA, maintaining administrative coherence.

To represent the department in such appeal proceedings, the same Principal Commissioner or Commissioner will take responsibility and can appoint any subordinate officer as the designated representative for filing departmental appeals before the Commissioner (Appeals).

Additionally, the circular provides that the reviewing or revisional authority may, before deciding on the O-I-O passed by the CAA, seek comments from the concerned DGGI formation which originally issued the show cause notice.

The CBIC has directed all field formations to issue suitable trade notices to publicize this procedural clarity among taxpayers and departmental officers alike. Stakeholders facing any difficulties in implementing these instructions have been advised to bring the matter to the Board’s notice for timely redressal.

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