GST Appellate Tribunal – A Step Closer to Reality

The journey of GST has always been about balancing uniformity with federal diversity. With the GST Appellate Tribunal (GSTAT) now inching closer to being operational, two important notifications dated 17th September 2025 provide much-needed clarity on where cases will be heard and by when appeals must be filed.

Jurisdiction – Where Will Your Appeal Lie?

Under Section 109 of the CGST Act, the Tribunal has a Principal Bench in New Delhi and State Benches across the country. Ordinarily, appeals will go before State Benches. But the law also reserves certain categories of disputes for the Principal Bench only.

Through Notification S.O. 4219(E), the Government has now clarified that:

• Disputes pending before two or more State Benches with the same legal issue will be heard centrally.
• Matters linked to Section 14 / 14A of IGST Act (supplies to or by SEZ, restrictions on refunds) will lie only before the Principal Bench.
• Cases under Section 20 of CGST Act (applicability of IGST provisions) too will go directly to New Delhi.

This ensures consistency in rulings where national uniformity is critical, especially for SEZ-related and cross-border supply cases.

Timelines – By When Must You File an Appeal?

Under Section 112, taxpayers normally have three months from communication of an order to file an appeal before GSTAT. But given that the Tribunal is becoming functional only now, the Government has provided a transitional window through Notification S.O. 4220(E):

• If your order was passed before 1st April 2026, you get time up to 30th June 2026 to file your appeal.
• For orders on or after 1st April 2026, the regular three-month time limit will apply.

This balances fairness with discipline – businesses with pending matters finally get a forum, but strict timelines will govern future appeals.