GSTAT revokes Staggered Filing of Appeals u/s 112, allows Unrestricted E-Filing from December 18 [Read Circular]

The Goods and Services Tax Appellate Tribunal ( GSTAT ) has now permitted unrestricted electronic filing of appeals with effect from December 18, 2025.

The GSTAT issued an order withdrawing its earlier direction mandating staggered filing of appeals under Section 112 of the Central Goods and Services Tax Act, 2017,

Earlier, by an order dated 24 September 2025, the GST Appellate Tribunal, exercising powers under Rule 123 of the GST Appellate Tribunal (Procedure) Rules, 2025, had directed that appeals under Section 112 be filed in a staggered manner.

This applied to appeals arising from orders passed by appellate and revisional authorities under Sections 107 and 108 of the CGST Act, read with the corresponding State and Union Territory GST laws.

The staggered filing mechanism was introduced primarily to manage portal load and ensure stability during the initial phase of GSTAT’s electronic filing system. The appeals were permitted to be filed only during specified windows, as detailed in a table appended to the September order.

However, after review, the Tribunal has now reassessed the technical readiness of the GSTAT portal. According to the latest order, the current assessment of the portal’s capabilities indicates that it can handle unrestricted access without compromising system efficiency.

Therefore, viewing that continuing with staggered filing was no longer necessary, it removed the restriction with effect from December 18, 2025.

Revocation of Earlier direction

Accordingly, the Tribunal has exercised its powers under Rule 123 to formally revoke the order dated 24-09-2025, with effect from 18-12-2025. From this date onwards, taxpayers and departments can file GST appeals under Section 112 without any limitation based on filing slots or phases

The Tribunal also clarified that the revocation does not affect the validity of appeals already filed under the earlier staggered filing regime. Any appeal lodged in accordance with the September 2025 order prior to December 18, 2025, will remain valid and unaffected.

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