GSTAT Procedure Rules Proposed Amendments: What Changed & What It Means for GST Litigation

GSTAT's Committee for Resolution of Representations from Trade and Bar Associations held its 3rd and 4th meetings on 29 May and 1 June 2026, under the chairmanship of Hon'ble (Dr.) Justice Sanjaya Kumar Mishra, President, GSTAT.

The minutes was issued on 10 June 2026 under F. No. GSTAT/Pr. Bench Jurisdiction/2026-27/173, recommend amendments to fifteen rules of the GSTAT (Procedure) Rules, 2025. These proposed amendments cover certified copies, filing requirements, translations, defect timelines, cause lists and fees.

II. Overview of the Proposed Amendments

The committee examined representations from practitioners, trade bodies, and bar associations across multiple GSTAT benches and produced rule-by-rule resolutions. Thirteen rules are recommended for amendment. Rules 21(5) and 108(2) were expressly left unchanged after deliberation.

The changes fall into six broad areas:

• Relaxation of certified copy and documentation requirements
• Digital-first submission replacing physical formalities
• Extended timelines for defect removal and scrutiny
• Restructured procedure for interlocutory applications
• Shift from daily to weekly cause lists
• Fee relief for rectification applications

III. Relaxation in Certified Copy Requirements

Rule 2(f): Definition of "Certified Copy"
Old Provision

"Certified copy" means the original copy of the order or the documents received by the party, or a copy thereof duly authenticated by the concerned department, or a copy duly authenticated by the authorised representative of the appellant or respondent.

Proposed Provision

"Certified copy" means the original copy of the order or the documents received by the party, or a copy thereof duly authenticated by an officer of the concerned department, or a copy duly authenticated by the appellant or respondent or their authorised representative.

What Changed and Why It Matters

Two targeted changes have been proposed.

First, "the concerned department" is replaced with "an officer of the concerned department". Authentication must come from a specific authorised officer, not an abstract departmental entity.

Second, the appellant or respondent can now authenticate a certified copy themselves. Under the old rule, only the authorised representative could do this. A self-represented taxpayer no longer needs to route this step through a CA or advocate.

IV. Procedural Changes in Appeal Filing

Rule 15(b): Powers and Functions of the Registrar
Old Provision

Notify the procedure of filing appeal to the Appellate Tribunal.

Proposed Provision

Notify the procedure of filing appeal to the Appellate Tribunal, as directed by the Tribunal.

What Changed and Why It Matters

The Registrar's power to notify filing procedures is now expressly subject to the Tribunal's direction. The Registry cannot unilaterally set or alter how appeals are filed. The Tribunal remains in control of the filing framework.

Rule 21(1): Documents Required to Accompany Form of Appeal
Old Provision

“Every Form of appeal required to be heard by the Appellate Tribunal shall be accompanied by a certified copy of the order appealed against in the case of an appeal against the original order passed by the adjudicating authority and where such an order has been passed in appeal or revision, there shall be a certified copy of the order passed in appeal or in revision along with the order of the original authority along with all the relevant documents including relied upon documents.

Provided that where an application filed under the direction of the Commissioner, the copy of the order appealed against shall be an attested copy instead of a certified copy.”

Proposed Provision

“Every Form of appeal required to be heard by the Appellate Tribunal shall be accompanied by a certified copy of the order appealed against and order of original adjudicating authority along with all documents including relied upon documents.

Provided that where an application filed under the direction of the Commissioner, the copy of the order appealed against shall be an attested copy instead of a certified copy.

Provided further that where the order appealed against is uploaded on the common portal, then the certified copy of the order appealed against need not be accompanied.”

What Changed and Why It Matters

Two improvements stand out.

First, the old chain-of-copies requirement is replaced by a streamlined requirement. The appeal now needs one certified copy of the impugned order plus the original adjudicating authority's order.

Second, a new proviso exempts filers from attaching a certified copy where the order is already on the GST common portal. Recent adjudication and first appellate orders are portal-based but this removes a major paperwork step at the GSTAT filing stage for a large number of matters.

Rule 21(2): Submission of Copy and Fees

Old Provision

“A certified copy of the decision or order appealed against along with fees as specified in sub-rule (5) of rule 110 of the Rules shall be submitted online and a final acknowledgement, shall be issued the Rules, by the GSTAT Portal.”

Proposed Provision

“A certified copy of the decision or order appealed against along with fees as specified in sub-rule (5) of rule 110 of the Rules shall be submitted online and a final acknowledgement, shall be issued under the Rules, by the GSTAT Portal.”

What Changed and Why It Matters

"The Rules" is corrected to "under the Rules." This is a grammatical correction only. The old rule read "issued the Rules", which was a drafting error. There is no change in substance or practice.

Rule 21(5): Attestation of Documents

No change.

The committee unanimously resolved that the existing provision, which empowers the President to authorise a gazetted officer or any other person to attest documents, is adequate and requires no amendment.

Rule 21(6): Format and Submission of Documents
Old Provision

“All relevant documents including relied upon documents shall be clearly legible, duly paged, indexed and tagged firmly.”

Proposed Provision

“All relevant documents including relied upon documents shall be clearly legible, duly paged, indexed and furnished online duly signed or verified through electronic verification code.”

What Changed and Why It Matters

"Tagged firmly", a physical filing requirement, is replaced with online submission verified by Electronic Verification Code. Document submission before GSTAT now aligns with GST compliance on the common portal. Physical bundles are no longer the centre of the filing process.

V. Translation and Documentation Requirements

Rule 23: Translation of Documents
Old Provision

“(1) A document other than English language intended to be used in any proceeding before the Appellate Tribunal shall be received by the Registry accompanied by a translated copy in English, which is agreed to by both the parties or certified to be a true translated copy by the authorised representative engaged on behalf of parties in the case.

(2) Appeal or other proceeding shall not be set down for hearing until and unless all parties confirm that all the documents filed on which they intend to rely are in English or have been translated into English and required number of copies are filed with the Appellate Tribunal.”

Proposed Provision

“(1) A document other than English language intended to be used in any proceeding before the Appellate Tribunal shall be received by the Registry accompanied by a translated copy in English, which is agreed to by both the parties or certified to be a true translated copy by the authorised representative engaged on behalf of parties in the case.

Provided that the Bench in its own discretion may relax the aforesaid requirement.

Sub-rule (2) is omitted entirely.”

What Changed and Why It Matters

Sub-rule (2) was the provision that directly caused listing delays.

It blocked matters from being set down for hearing until every document was translated into English. This created a serious practical problem where adjudication orders and relied upon documents were in regional languages, which is routine across Tamil Nadu, Maharashtra, West Bengal, Andhra Pradesh, Telangana, and Kerala.

Sub-rule (2) is now deleted. The Bench has discretion under the new proviso to waive the translation requirement where appropriate. This allows matters to proceed without being held back by translation backlogs.

VI. Defect Rectification and Scrutiny of Appeals

Rule 24: Endorsement and Scrutiny of Petition or Appeal or Document
Old Provision

“(1) If, on scrutiny, the appeal, application or any other document is found to be defective, such document shall, after notice to the party, be returned for compliance and if there is a failure to comply within seven working days from the date of return, the same shall be placed before the Registrar who may pass appropriate orders.

(2) The Registrar may for sufficient cause return the said documents for rectification or amendment to the party filing the same, and for this purpose may allow to the party concerned such reasonable time as he may consider necessary or extend the time for compliance, in any case not exceeding thirty days from the date of filing of the said documents.

(3) Where the party fails to take any step for the removal of the defect within the time fixed for the same, the Registrar may, for reasons to be recorded in writing, decline to register the appeal or pleading or document.

(4) Where, after a personal hearing, the Registrar is not satisfied with the steps taken by the party for removal of defects, he shall list the same with defects for hearing before the appropriate bench of the Tribunal and the Bench may, after hearing the party, accept to register the appeal or may, in its discretion, reject the said appeal.”

Proposed Provision

“(1) If, on scrutiny of the appeal, application or any other document, it is found to be defective, then the Registrar shall issue a notice to the party, intimating the defects on the GSTAT portal, for removal of defects, compliance or amendments or rectification, within a period of fifteen working days from the date of issuance of such notice.

(2) The Registrar may request the party concerned for rectification or amendment of the document, and for this purpose may offer personal hearings and may allow to the party concerned such reasonable time as he may consider necessary or extend the time for compliance, in any case not exceeding forty-five days from the date of filing of the said documents.

(3) Where the party fails to take any step for the removal of the defect within the time fixed for the same, or the Registrar is not satisfied with the steps taken by the party for removal of defects, the Registrar may record the observations in writing.

(4) After recording the observations in writing, the Registrar shall list the same with defects for hearing before the appropriate bench of the Tribunal and the Bench may, after hearing the party, accept to register the appeal or may, in its discretion, reject the said appeal.”

What Changed and Why It Matters

Rule 24 is the most substantively rewritten rule in this set. Three concrete improvements have been proposed.

First, the timelines are extended. The initial cure period increases from seven working days to fifteen working days after the Registrar's notice. The outer compliance limit increases from thirty days to forty-five days from filing.

Second, the Registrar must issue a formal defect notice on the GSTAT portal. This creates a documented record of what defects were identified and when the clock began.

Third, the Registrar must record observations in writing before listing the matter before a Bench. This creates documented accountability at the Registry level and gives the appellant full notice of the Registrar's specific objections before escalation.

Rule 26: Ex-Parte Amendments
Old Provision

“In every appeal or application, arithmetical, grammatical, clerical and such other errors may be rectified on the orders of the Registrar without notice to parties.

Provided that no amendments shall be allowed ex-parte after appearance of the respondents.”

Proposed Provision

“In every appeal or application, arithmetical, grammatical or clerical errors may be rectified on the orders of the Registrar without notice to parties.

Provided that no amendments shall be allowed ex-parte after appearance of the respondents.”

What Changed and Why It Matters

"And such other errors" is deleted. "Or" is inserted between grammatical and clerical.

The phrase "such other errors" was open-ended and gave the Registrar a wider ex-parte rectification power. The amendment confines ex-parte rectification to three defined categories only: arithmetical, grammatical, or clerical.

The proviso prohibiting ex-parte amendments after the respondent appears remains unchanged.

VII. Changes Relating to Interlocutory Applications

Rule 29: Interlocutory Applications
Old Provision

“Every interlocutory application for stay, direction, rectification in order, condonation of delay, early hearing, exemption from production of copy of order appealed against or extension of time prayed for in pending matters shall include all the information as per the prescribed GSTAT FORM-01 and the requirements prescribed in that behalf shall be complied with by the applicant, besides filing an affidavit supporting the application.”

Proposed Provision

“An interlocutory application can be filed only for stay, direction, rectification in order, condonation of delay, early hearing, exemption from production of copy of order appealed against or extension of time prayed for in pending matters, restoration or other interim prayers and shall include all the information as per the prescribed GSTAT FORM-01 and the requirements prescribed in that behalf shall be complied with by the applicant, besides filing an affidavit supporting the application.

Provided that for adjournment of hearing date of appeals or applications listed, the filing of an interlocutory application is not mandatory.”

What Changed and Why It Matters

"Restoration or other interim prayers" is added as a recognised IA ground. This closes a gap where practitioners had no express authority for restoration applications. Seeking an adjournment no longer requires a formal IA with affidavit. Under the old rule, a date change in a listed matter required GSTAT FORM-01 and affidavit. That requirement is removed for adjournments, reducing routine paperwork across all GSTAT benches.

VIII. Pleadings, Replies and Cross-Objections

Rule 22: Endorsement and Verification
Old Provision

“At the foot of every appeal or pleading along with all the relevant documents including relied upon documents, there shall appear the name and signature of the authorised representative and every appeal or pleadings shall be signed and verified by the party concerned in the manner provided by these rules.”

Proposed Provision

The existing provision remains unchanged. A Note has been inserted after it:

"Note: For the purpose of preferring an appeal / filing an appeal properly, one verification of the appellant containing the statement that 'The contents of the statement of facts, grounds of appeal and the annexures filed as documents are true and correct to his best knowledge, belief and information,' with an identification by the advocate, tax professionals in Form APL-05."

What Changed and Why It Matters

The Note clarifies that a single verification by the appellant is sufficient where it confirms that facts, grounds, and annexures are true to the appellant's best knowledge. The verification must be accompanied by identification by the advocate or tax professional in Form APL-05.

This means one sign-off by the appellant and one identification by the professional. This was adopted 5 to 1, with the Chennai Bench member dissenting on record.

Rule 35: Head Note of the Rule
Old Provision

“Filing of Form of cross-objections, applications or replies to appeals or applications.”

Proposed Provision

“Filing of Form of cross-objections to Appeals or applications or replies to applications.”

What Changed and Why It Matters

This is a drafting correction. "Replies to appeals or applications" is replaced with "replies to applications". This clarifies that replies under this rule are to applications specifically, not to appeals generally.

Rule 36: Filing of Reply and Other Documents by Respondents
Old Provision

“(1) Each respondent may file his reply to the petition or the application and copies of the documents, either in person or through an authorised representative, with the registrar as specified by the Appellate Tribunal within one month of the receipt thereof. A copy of such reply and the copies of other documents shall be forthwith served on the applicant by the respondent.”

Proposed Provision

“(1) Each respondent may file his reply to the petition or the application and copies of the documents, either in person or through an authorised representative, with the registrar as specified by the Appellate Tribunal within one month of the receipt thereof or within such time as may be specified or extended by the Bench. A copy of such reply and the copies of other documents shall be forthwith served on the applicant by the respondent.”

What Changed and Why It Matters

One month was previously a hard outer limit with no express power to extend. Benches now have formal authority to specify or extend the reply timeline. Respondents, including the department, can seek more time without relying on implied powers.

Rule 37: Filing of Rejoinder
Old Provision

“Where the respondent states such additional facts as may be necessary for the just decision of the case, the Bench may allow the petitioner to file a rejoinder to the reply filed by the respondent on the GSTAT portal, with an advance copy to be served upon the respondent within one month or within such time as may be specified or extended by the Bench.”

Proposed Provision

“Where the respondent states such additional facts as may be necessary for the just decision of the case, the Bench may allow the petitioner to file a rejoinder to the cross objections filed by the respondent on the GSTAT portal, with an advance copy to be served upon the respondent within one month or within such time as may be specified or extended by the Bench.”

What Changed and Why It Matters

"Reply" is replaced with "cross objections."

A reply and cross-objections are distinct pleadings. A rejoinder is a response to cross-objections, not to the reply. The amendment corrects the terminology and removes ambiguity about when a rejoinder is filed.

IX. Cause Lists and Case Management Reforms

Rule 38: Preparation and Publication of Cause List
Old Provision

(1) The Registrar shall prepare and publish the cause list for the next working day, which shall include all the information as specified in GSTAT CDR-01, on the notice board of the Appellate Tribunal and GSTAT Portal before the closing of working hours on each working day.

(2) Subject to the directions of the President, listing of cases in the daily cause list shall be in the following order of priority, unless otherwise ordered by the concerned Bench.

(4) The title of the daily cause list shall consist of the number of the appeal, the day, date and time of the sitting, Bench Hall number and the coram indicating the names of the Judicial members and Technical Members constituting the Bench.

(5) Against the number of each case listed in the daily cause list, the following shall be shown.

Proposed Provision

(1) The Registrar shall prepare and publish the cause list for the next week, which shall include all the information as specified in GSTAT CDR-01, on the notice board of the Appellate Tribunal and GSTAT Portal before the closing of working hours on the last working day of the previous week.

(2) Subject to the directions of the President, listing of cases in the weekly cause list shall be in the following order of priority, for each working day of the week for the Bench, unless otherwise ordered by the concerned Bench.

(4) The title of the weekly cause list shall consist of the number of the appeal, the day, date and time of the sitting, Bench Hall number and the coram indicating the names of the Judicial members and Technical Members constituting the Bench.

(5) Against the number of each case listed in the weekly cause list, the following shall be shown.

Provided that on the discretion of President, Vice-President or member presiding of the Bench, a supplementary list may be published.

What Changed and Why It Matters

The shift from daily to weekly cause list publication is the most operationally significant change in this set. Under the old system, the next day's cause list was published at the end of the working day. This gave practitioners very limited time to plan hearings, travel, and client coordination.

Under the new system, the full week's list is published by the close of the last working day of the previous week. This gives advance notice for the entire following week. The proviso preserving the power to publish a supplementary list ensures that urgent matters, including stay matters and court-directed listings, are still listed at short notice.

Rule 39: New Cause List on Non-Sitting Days

Old Provision

(1) If by reason of declaration of holiday or for any other unforeseen reason, the Appellate Tribunal does not function for the day, the new daily cause list shall be prepared for the cases listed for the day.

Proposed Provision

(1) If by reason of declaration of holiday or for any other unforeseen reason, the Appellate Tribunal does not function for the day, the new cause list shall be prepared for the cases listed for the day, by suitably incorporating the listed cases for a subsequent day or days as directed by the Bench.

What Changed and Why It Matters

The old rule left rescheduling unclear. Parties had to keep checking the portal to find out when their matter was relisted. The amendment removes that uncertainty. The Bench directs when carried-over cases will be listed, giving practitioners a clearer rescheduled date.

X. Rectification of Orders and Fee-Related Amendments

Rule 108(2): Rectification of Order, Limitation
Old Provision

(2) An application under sub-rule (1) shall be made online which shall include all the information as prescribed in GSTAT FORM-01 within one month from the date of the final order for rectification.

Proposed Provision

No change. The committee unanimously resolved that Rule 108(2) requires no amendment.

What Changed and Why It Matters

There is no change, and the reasoning matters. Rule 108(2) gives a party one month to file a rectification application. Section 113(3) of the CGST Act limits the Tribunal's own power to amend its order to three months.

If the party's filing window is extended but the Tribunal's statutory jurisdictional limit is not changed, a party could file in time but the Tribunal would have no jurisdiction to act by the time it considers the application. The committee left both provisions unchanged to avoid that mismatch.

Rule 119: Fees
Old Provision

Fee-related provisions linked to Rule 110(5) of CGST Rules, 2017. No specific provision regarding rectification applications.

Proposed Provision

Fee-related provisions linked to Rule 110(5) of CGST Rules, 2017, unchanged for the general fee schedule.

Provided further that there shall be no fee for an application made before the Appellate Tribunal for rectification of errors referred to in sub-section (10) of section 112 of the CGST Act.

What Changed and Why It Matters

The overall fee schedule under Rule 110(5) of the CGST Rules, 2017 is outside the committee's jurisdiction. The committee noted that ITAT and CESTAT charge comparatively lower fees and referred the broader question to the Ministry of Finance. No fixed timeline has been provided.

Within its jurisdiction, the committee inserted one specific proviso: no fee for rectification applications under Section 112(10) of the CGST Act. Rectifying an apparent error in a GSTAT order is a corrective step. Charging a fee for it was unjust, and that has now been corrected.

XI. Key Implications for GST Litigation

For taxpayers and businesses filing appeals

• Portal-uploaded orders no longer need a certified copy attached under Rule 21(1). This removes a major paperwork hurdle at the GSTAT filing stage.
• Self-represented taxpayers can authenticate their own certified copies under Rule 2(f).
• Defect cure windows are wider. The time to respond to a defect notice increases from seven working days to fifteen working days. The outer compliance limit increases from thirty days to forty-five days from filing.
• All defect notices will appear formally on the GSTAT portal with a documented digital record.
• Weekly cause lists published by Friday give advance planning time for hearings, travel, and client coordination.
• Adjournments no longer require a formal IA with affidavit under Rule 29.
• Mandatory written observations under Rule 24 before escalation to a Bench protect clients from undocumented or informal rejections.
• Regional-language practitioners benefit directly from the deletion of Rule 23(2). Matters will not be blocked from listing merely because translations are pending.

For advocates and tax professionals
For the department and respondents

Benches now have express power to extend reply timelines under Rule 36. This removes reliance on implied procedural powers.

On fees

No fee is payable for rectification applications under Section 112(10) of the CGST Act. This gives immediate relief for a recurring category of applications before GSTAT.

Conclusion

The proposed amendments address real problems that emerged once GSTAT became operational. The portal-order exemption from certified copy requirements, weekly cause list, extended defect timelines, removal of the translation bar, and elimination of the IA requirement for adjournments reduce the cost and procedural friction of pursuing a GST appeal. These are committee recommendations and are not yet in force.

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