O.2 Master filing checklist

In the order the work is actually done. Every item names the sub-rule that bites, so an objection at the counter can be answered from the checklist itself.

Stage 1 — Before anything is drafted

• ☐ The impugned order is an order under s.107 or s.108 — an order-in-appeal or a revisional order. Not an order-in-original, which goes to the Appellate Authority first
• ☐ The order is not excluded by s.121 (non-appealable decisions)
• ☐ Date of communication fixed, and proof of it placed on file
• ☐ Limitation computed under Part O.1, and the s.112(6) outer limit diarised at the same sitting
• ☐ Grounds tested against the place-of-supply proviso, s.109(5) — one such issue and the appeal lies to the Principal Bench, and thereafter to the Supreme Court, not the High Court
• ☐ Amount checked against s.112(2) (₹50,000 admission discretion)
• ☐ s.112(8)(a) — admitted tax, interest, fine, fee and penalty paid in full
• ☐ s.112(8)(b) — 10% of the disputed tax, in addition to the s.107(6) deposit, capped at ₹20 crore. Base excludes interest and penalty
• ☐ Penalty-only order? Then the proviso to s.112(8) applies instead: 10% of the penalty, in addition to the 10% payable under the proviso to s.107(6) — inserted by Notn 16/2025-CT, w.e.f. 01.10.2025. The old 25% figure for s.129(3) orders is gone
• ☐ Ledger used for the deposit noted; the contested credit-ledger point considered on the client's own facts

Stage 2 — Structuring the appeal

• ☐ One appeal per order-in-appeal — r.18(2). The number of show cause notices, refund claims, demands, letters or declarations dealt with makes no difference
• ☐ But: if the order-in-appeal deals with more than one order-in-original, file as many appeal Forms as there are orders-in-original so far as this appellant is concerned — r.18(3)(a)
• ☐ And: if the impugned order is in respect of more than one person, each aggrieved person files separately. Common and joint appeals shall not be entertained — r.18(3)(b)
• ☐ Cause title reads "In the Goods and Service Tax Appellate Tribunal" and sets out the proceedings or order appealed against — r.18(1)(a)
• ☐ Body divided into consecutively numbered paragraphs, one fact, allegation or point to a paragraph — r.18(1)(b)
• ☐ Full name, parentage, GSTIN, description and address of each party set out at the beginning; not repeated later in the same appeal — r.18(1)(c)
• ☐ Parties numbered consecutively, one line each; numbers never changed; on a death during pendency, legal heirs shown by sub-numbers — r.18(1)(d)

Stage 3 — Grounds and form

• ☐ Grounds set out concisely, under distinct heads, consecutively numbered — r.20(1)
• ☐ Typed in double space, on A4 — r.20(1), (2)
• ☐ Duly paged, indexed and tagged firmly in a separate folder — r.20(2). This applies equally to cross-objections, reference applications, stay applications and any other miscellaneous application
• ☐ Signed and verified by the appellant, applicant, respondent or authorised representative — r.20(3)
• ☐ Documents certified as true copies by the signatory — r.20(3)
• ☐ Name and signature of the authorised representative at the foot of the appeal and of every pleading and relied-upon document — r.22
• ☐ Remember r.31: grounds not set out in the Form cannot be urged except by leave

Stage 4 — Documents that must accompany

• ☐ Certified copy of the order appealed against — r.21(1)
• ☐ Where that order was itself passed in appeal or revision, also a certified copy of the order of the original authority — r.21(1)
• ☐ All relevant documents including relied-upon documents — r.21(1)
• ☐ Everything clearly legible, duly paged, indexed and tagged firmly — r.21(6)
• ☐ Departmental filing under the Commissioner's direction: an attested copy suffices, not a certified copy — proviso to r.21(1)
• ☐ Before applying for exemption from producing a copy, exhaust r.2(1)(f) — a certified copy includes the original received by the party and a copy authenticated by the authorised representative. Most supposed need for exemption disappears here
• ☐ Any document not in English accompanied by a translation agreed by both parties or certified by an authorised representative — r.23(1). The matter will not be set down for hearing until every party confirms this — r.23(2)
• ☐ Any defaced, torn or damaged document: its condition noted in the Index, and verified and initialled by the receiving officer — r.30

Stage 5 — Fee, authority and filing

• ☐ Appeal fee under CGST r.110(5) — ₹1,000 for every ₹1 lakh of tax, ITC, fine, fee or penalty determined by the order, max ₹25,000, min ₹5,000; flat ₹5,000 where the order involves no demand. Item 3 of the GSTAT Schedule says only "As per rule" and remits it; r.21(2) does the same through r.2(1)(p)
• ☐ Restoration of an appeal is charged on that same scale — CGST r.110(5) says "appeal or restoration of appeal". Not ₹5,000 under Schedule item 2
• ☐ Rectification under s.112(10) carries NO FEE — CGST r.110(6). Do not pay, and do not let the Registry charge it as an interlocutory application
• ☐ Any other interlocutory application carries ₹5,000 — Schedule of Fees item 2 (Gazette p.63). Departmental applications: no fee (provisos to r.119(1) and (2))
• ☐ Fee paid on the GSTAT Portal in the manner provided there — r.119(3)
• ☐ Vakalatnama, Memorandum of Appearance or letter of authorisation on GSTAT FORM-04, duly executed — r.72
• ☐ Replacing an existing representative: written consent of the one on record, or the Tribunal's permission after revocation, on an application served on him — r.73. Not required for a s.112(3) departmental application
• ☐ Authorisation of the signatory available for the Registrar — r.28
• ☐ Filed online — GSTAT r.18(1) and r.115, and now compulsorily: Notification 13/2025-CT omitted the manual-filing provisos in CGST rr.110 and 111 w.e.f. 22 September 2025. GSTAT r.19's "if the appeal is filed manually" is largely spent
• ☐ Provisional acknowledgement in Part A of FORM GST APL-02A obtained and kept — CGST r.110(4)
• ☐ Where the order appealed against is not on the common portal, a self-certified copy uploaded within seven days; miss it and the date of filing shifts to the date of submission — provisos to CGST r.110(4)
• ☐ Final acknowledgement in Part B of FORM GST APL-02A, indicating the appeal number — the appeal "shall be treated as filed only when" it issues (Explanation to CGST r.110(4)); GSTAT r.21(2) says the same from its side. Keep it

Stage 6 — Immediately after filing

• ☐ A copy of the appeal and all relevant and relied-upon documents served on the respondent and on the concerned Commissioner "as soon as they are filed" — r.34. This is not optional and not deferred to the hearing
• ☐ Watch for scrutiny under r.24. A returned document must be cured within seven working days of return, and in any event within the Registrar's outer limit of thirty days from filing
• ☐ On registration, note the appeal number entered under r.25 and in GSTAT CDR-04
• ☐ Diarise the respondent's reply within one month of receipt (r.36(1)) and your own obligation under r.36(2) to admit, deny or rebut specifically
• ☐ Open the adjournment ledger now: three per party, s.113(2)

O.3 Defect table

What the Registry actually returns papers for, the provision it acts under, and the cure. Rules 24 and 32 are two distinct machineries and are often confused; the difference is set out after the table.

O.3.1 Rule 24 and rule 32 are not the same machinery

The number point, which costs money

Both r.21(3) and r.32(5) carry the same sting: a returned or rejected filing that is later accepted may be assigned a new number. A new number is a new date of institution for every practical purpose the Registry cares about. Where the s.112(1) period has since expired, the appellant is arguing sufficient cause under s.112(6) for a delay he created by filing badly.