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GST Notices · Appeals · GSTAT · Section 73 / 74 / 74A

GST notice? Win it at the reply — or take it all the way to GSTAT.

Most GST disputes are decided by the first reply — and every appeal relies on the record made there. We check limitation and section first (73/74 up to FY 2023-24, 74A from FY 2024-25), reconcile your returns, reply with evidence and attend the hearing. If an order goes against you, we compute the 10% pre-deposit (capped at ₹20 crore each head) and file the appeal — including to the GST Appellate Tribunal, hearing cases since February 2026. 93% of our notices close at the first reply.

93%Notices closed at first reply
GSTAT liveHearing appeals since Feb 2026
10% + 10%Pre-deposit · first appeal + GSTAT
From ₹3,500Notice reply
✓ 93% notices closed at first reply · 4.9★ · 549 Google reviews
MOST POPULARFirst Appeal · APL-01 with hearing
First Appeal
₹9,000
₹10,620 incl. 18% GST
from · + GST · pre-deposit (10% of disputed tax) is paid to the government, separately
EVERYTHING INCLUDED
  • Notice diagnosis: section, period, limitation and quantum
  • Reply drafted with reconciliations and evidence
  • Personal hearing representation
  • Pre-deposit computation + deadline tracking
  • First appeal (APL-01) and GSTAT appeal (APL-05)
  • Rectification, stay of recovery and follow-up
Book on WhatsApp — free notice review
Just received a notice? Notice Reply (from ₹3,500)
Our feeFrom ₹3,500
First appeal3 months · 10%
GSTAT3 months · +10%
Pre-deposit cap₹20 Cr each head
Track record93% closed at reply
Send us your notice
93% notices closed at first reply
GSTAT hearing since Feb 2026
★ 4.9/5 · 549 Google reviews
10% pre-deposit · ₹20 Cr cap
74A from FY 2024-25
5,000+ businesses served
93% notices closed at first reply
GSTAT hearing since Feb 2026
★ 4.9/5 · 549 Google reviews
10% pre-deposit · ₹20 Cr cap
Understand the basics

The GST dispute framework in 2026

Four forums — officer, Appellate Authority, GSTAT, High Court — each with its own time limit and pre-deposit. The Tribunal that was missing for eight years is now hearing cases. And the section that governs your dispute depends on the financial year.

The forums:

  • Officer: ASMT-10, DRC-01A, DRC-01 → order DRC-07
  • Appellate Authority: APL-01 within 3 months
  • GSTAT: APL-05 within 3 months — hearing since 16 Feb 2026
  • High Court: substantial questions of law

Pre-deposit:

  • First appeal: 10% of disputed tax, max ₹20 Cr each CGST, SGST/IGST
  • GSTAT: further 10%, max ₹20 Cr each
  • Penalty-only orders: 10% of penalty
  • Valid appeal + pre-deposit → recovery of balance stayed

Which section:

  • Up to FY 2023-24: Sections 73 (3 yrs) / 74 (5 yrs)
  • FY 2024-25 onward: Section 74A — notice within 42 months

Deadlines already passed:

  • GSTAT backlog (orders before 1 Apr 2026): 30 June 2026
  • Section 128A waiver: tax by 31 March 2025
GST DISPUTE LADDER Win it as early as possible Notice ASMT-10 · DRC-01 Order DRC-07 1st Appeal APL-01 · 10% GSTAT APL-05 · +10% Cost and time rise at each step · the record is set at step one 3 months ₹20 Cr cap Stay of recovery 74A: 42 months GSTAT live Hearing right ✦ 93% of our notices closed at the first reply

Talk to us if...

  • You've received an ASMT-10 scrutiny notice, DRC-01A intimation or DRC-01 show cause notice and the reply window is running
  • An adverse order (DRC-07) has been passed and you need to decide — rectify, pay, or appeal within 3 months
  • You lost a first appeal and want to take it to GSTAT, which has been hearing cases since February 2026
  • The dispute is about ITC mismatch, GSTR-2B vs 3B, classification, place of supply or e-way bills
  • The notice may be time-barred or issued under the wrong section — 73/74 for FY 2023-24 and earlier, 74A from FY 2024-25
  • Recovery action (bank attachment) has started and you need the stay that a valid appeal with pre-deposit brings
The 6 core benefits

What our GST litigation practice delivers

Replies that end disputes early · limitation and section checked first · pre-deposit computed and planned · GSTAT appeals · hearings handled · honest pay-or-appeal advice.

Replies That End Disputes Early

Most GST disputes are won or lost at the reply stage. A reply that reconciles GSTR-1, 3B, 2B and books, attaches invoices and payment proofs, and addresses each allegation specifically closes most notices without an adverse order. Our firm has closed 93% of notices at the first reply. The reply is also the record every appeal later relies on — weak replies make appeals harder.

Limitation and Section Checked First

Before arguing the merits, we check whether the notice is valid. Periods up to FY 2023-24 fall under Sections 73 and 74 (orders within 3 and 5 years of the annual-return due date). From FY 2024-25, Section 74A applies: notice within 42 months of the annual-return due date, order within 12 months, no notice where tax is under ₹1,000. A notice issued late, or under the wrong section, can fail on that alone.

Pre-deposit Computed — and Planned

A first appeal needs a pre-deposit of 10% of the disputed tax, capped at ₹20 crore each for CGST and SGST/IGST since 1 November 2024. A GSTAT appeal needs a further 10% of the tax in dispute, again capped at ₹20 crore each. Finance Act 2025 added a 10% pre-deposit for penalty-only orders. Once paid with a valid appeal, recovery of the balance is stayed. We compute it precisely, and plan the cash.

GSTAT — The Missing Forum Is Live

For eight years there was no second-appeal forum, and taxpayers had to go to High Courts. The GST Appellate Tribunal was launched on 24 September 2025 and began hearing cases on 16 February 2026, with a Principal Bench in New Delhi and State Benches. Appeals are filed online in APL-05 within 3 months of the first-appeal order; place-of-supply disputes go to the Principal Bench.

Personal Hearings Handled

You have a right to be heard before an adverse order. We attend personal hearings with the officer or appellate authority, present reconciliations, and file written submissions afterwards so the record is complete. Many disputes turn on explaining a mismatch clearly to the person deciding it.

Honest Assessment Before You Spend

Not every order is worth appealing. We tell you whether to pay, rectify or appeal, what the pre-deposit and costs will be, and how strong the grounds are — before you commit money. For small demands with weak grounds, closing the dispute can be cheaper than litigating it.

Video walkthrough · coming soon

Coming soon: from GST notice to GSTAT

Notice types → limitation checks → reconciled replies → hearings → orders → pre-deposit → first appeal → GSTAT. In 2 minutes.

Video coming soon

GST disputes · Notice to Tribunal

Which section applies to which year, how to count appeal deadlines, what pre-deposit really costs, and why the reply stage decides most cases.

The complete GST dispute lifecycle

3-stage journey · Notice to Tribunal

Red = notice and reply. Gold = order and first appeal. Purple = GSTAT. Every clock starts from the date of communication, and every later stage works from the record built at the first.

STAGE 1 · NOTICE · REPLY WINDOW DAY 0 Diagnose Section · period · limitation DAYS 1-10 Reconcile GSTR-1 · 3B · 2B · books BY DUE DATE Reply DRC-06 + evidence HEARING Represent Written submissions STAGE 2 · ORDER · 3 MONTHS TO ACT ORDER DRC-07 Review Rectify · pay · appeal DECIDE Honest View Grounds vs cost 10% Pre-deposit ≤₹20 Cr each head APL-01 First Appeal Recovery of balance stayed STAGE 3 · GSTAT · SECOND APPEAL APL-04 First-Appeal Order 3 months clock starts +10% Further Pre-deposit ≤₹20 Cr each head APL-05 efiling.gstat.gov.in Paper book BENCH Hearing High Court on law ✦ Count every deadline from the date of communication · backlog GSTAT deadline for pre-Apr-2026 orders was 30 Jun 2026
← Swipe horizontally to see all phases →
Day 0

Diagnose

Notice type, section, period, limitation and quantum.

Days 1-10

Reconcile

GSTR-1, 3B, 2B and books; supplier-wise ITC trails.

By due date

Reply + Hearing

Allegation-by-allegation reply with evidence; personal hearing.

Order

Decide

Rectify, pay or appeal — with pre-deposit and costs laid out.

+3 months

First Appeal

APL-01 with 10% pre-deposit; recovery of balance stayed.

+3 months

GSTAT

APL-05 with further 10%; Bench hearing.

The stages of a GST dispute

6 eligibility scenarios

✓
Scrutiny (ASMT-10)The officer flags discrepancies in your returns and asks for an explanation, typically within 30 days. A clear reconciliation here often ends the matter; if accepted, proceedings close. If not, a show cause notice can follow.
✓
Pre-SCN intimation (DRC-01A) and SCN (DRC-01)Before a show cause notice, you may get an intimation (DRC-01A) and can pay or object. A show cause notice under Section 73, 74 or 74A sets out the demand, interest and penalty; reply in DRC-06 within the time given, with evidence, and ask for a personal hearing.
✓
Order (DRC-07) and rectificationThe adjudication order confirms, reduces or drops the demand. Errors apparent on the record can be rectified. Otherwise you choose: pay (penalty relief may apply in non-fraud cases) or appeal.
✓
First appeal (APL-01)To the Appellate Authority within 3 months of the order (1 more month on sufficient cause), with 10% of disputed tax (max ₹20 crore each CGST and SGST/IGST) — or 10% of penalty for penalty-only orders. Paying the pre-deposit stays recovery of the balance.
✓
Second appeal to GSTAT (APL-05)Against the first-appeal order, within 3 months (the Tribunal may condone up to 3 more months for sufficient cause), with a further 10% of the tax in dispute (max ₹20 crore each). Orders communicated before 1 April 2026 had a special deadline of 30 June 2026, which has passed.
✓
High Court and beyondAppeals from GSTAT to the High Court lie on substantial questions of law, and writ petitions remain available for jurisdictional or natural-justice failures. With GSTAT operational, High Courts increasingly expect taxpayers to use the Tribunal first.
What to send us

Documents for a reply or appeal

The notice or order, your returns and reconciliations, and the evidence behind them. A photo of the notice on WhatsApp is enough to start — we'll tell you what else is needed.

Notice / Order

  • The notice or order (ASMT-10, DRC-01A, DRC-01, DRC-07, APL-04)
  • Date of communication (portal / email / physical)
  • Any earlier replies and hearing records
  • Pre-deposit challans already paid
  • Rectification applications, if filed
  • Recovery / attachment notices, if any

Returns + Reconciliations

  • GSTR-1, GSTR-3B for the period
  • GSTR-2A / 2B statements
  • GSTR-9 / 9C (annual return, reconciliation)
  • Books: purchase and sales registers, ledger extracts
  • E-way bills and e-invoices (where relevant)
  • Electronic credit and cash ledger statements

Evidence

  • Tax invoices, debit / credit notes
  • Payment proofs to suppliers (for ITC)
  • Transport documents, delivery proofs
  • Contracts and purchase orders
  • Supplier confirmations / GSTR-1 of suppliers
  • Any rulings or circulars you rely on
Live deadline + pre-deposit calculator

When is your deadline, and what will it cost to appeal?

Enter the disputed tax (or penalty, for penalty-only orders), the stage and the date the order was communicated. Shows the pre-deposit for this stage (10%, capped at ₹20 crore per head), the statutory deadline, the discretionary outer limit and days remaining from today.

Only the part you are contesting
Cap applies to each head separately
Used only if the order is penalty-only
Deadlines run from communication, not the date printed on the order
Your pre-deposit + deadline
Stage—
Pre-deposit · CGST—
Pre-deposit · SGST / IGST—
Pre-deposit · penalty-only—
Pre-deposit this stage —
Cumulative (both stages)—
Statutory deadline—
Outer limit (condonation)—
Days remaining—
Illustrative. Pre-deposit is on the disputed tax only; the cap is ₹20 crore per head. Cumulative assumes the same disputed amount at both stages. Condonation is discretionary and should never be relied on. For GSTAT appeals against first-appeal orders communicated before 1 April 2026, the special deadline was 30 June 2026.
Reply vs first appeal vs GSTAT

Reply vs first appeal vs GSTAT · What each stage involves

Three stages, three forums, rising cost and time. The comparison shows why the reply stage deserves the most effort.

CriteriaNotice replyFirst appeal (APL-01)GSTAT appeal (APL-05)
ForumProper officerGST Appellate Tribunal
AgainstASMT-10 / DRC-01A / DRC-01First-appeal order (APL-04)
Time limitAs stated in notice (often 30 days)3 months (+up to 3 months)
Pre-depositNoneFurther 10% of disputed tax
Cap—₹20 Cr each CGST, SGST/IGST
Penalty-only orders—10% of penalty
RecoveryNot yet dueBalance stayed on pre-deposit
FilingGST portal (DRC-06 etc.)efiling.gstat.gov.in
HearingPersonal hearing with officerBefore a Bench
EvidenceMain opportunityFinal fact-finding forum
Typical outcome timeWeeks to monthsMonths to over a year
Place of supplyOfficerPrincipal Bench, New Delhi
Small cases—May decline if ≤₹50,000
Best chance to winHighest · cheapestDepends on record below
Our feeFrom ₹3,500From ₹18,000
Next stepOrderHigh Court (question of law)
← Swipe to see all columns →
Full landscape

India GST dispute map · 6 stages in one chart

Notice types, which section governs which year, first appeal, GSTAT, the deadlines that have already passed, and what lies beyond the Tribunal.

India GST Dispute Map · 2026 · 6 Stages Organised by Forum Notice → reply → order → first appeal → GSTAT → High Court · with pre-deposits, time limits and the sections that govern each period NOTICE STAGE · THE CHEAPEST AND MOST EFFECTIVE PLACE TO WIN ASMT-10 Scrutiny of returns Explain discrepancies Often ~30 days DRC-01A Pre-SCN intimation Pay or object Before the SCN DRC-01 (SCN) Demand + interest + penalty proposed Reply in DRC-06 Hearing Right to be heard Present reconciliations Written submissions WHICH SECTION · SET BY THE FINANCIAL YEAR IN DISPUTE Section 73 Up to FY 2023-24 Non-fraud Order ≤3 yrs of GSTR-9 due Section 74 Up to FY 2023-24 Fraud / suppression Order ≤5 yrs Section 74A FY 2024-25 onward Notice ≤42 months Order ≤12 months De minimis 74A: no notice if tax < ₹1,000 Non-fraud: 10% / ₹10k FIRST APPEAL · APL-01 · APPELLATE AUTHORITY Time Limit 3 months from communication +1 month for cause Pre-deposit 10% of disputed tax Cap ₹20 Cr each CGST · SGST/IGST Penalty-only 10% of penalty Finance Act 2025 Recovery Balance stayed on valid appeal + pre-deposit GSTAT · APL-05 · LAUNCHED 24 SEP 2025 · HEARING SINCE 16 FEB 2026 Time Limit 3 months from APL-04 +up to 3 months Pre-deposit Further 10% Cap ₹20 Cr each Disputed tax Benches Principal: New Delhi State Benches Place of supply: PB Filing efiling.gstat.gov.in Fully online ≤₹50k may be declined DEADLINES THAT HAVE PASSED · CHECK YOUR OLD ORDERS GSTAT Backlog Orders before 1 April 2026 Deadline 30 Jun 2026 Section 128A Waiver FY 17-18 to 19-20 Tax paid by 31 March 2025 Condonation? Beyond statutory windows: uncertain Seek advice now Recovery Can proceed if no timely appeal CBIC Circ. 224/2024 BEYOND GSTAT · AND HOW TO AVOID NEEDING IT High Court Substantial question of law After GSTAT Writ Jurisdiction or natural justice GSTAT preferred first Pay Early Non-fraud cases Penalty relief Within set windows Reconcile GSTR-1 · 3B · 2B Books monthly Prevent notices Most disputes are won at the reply stage · every appeal relies on the record made there Notice reply from ₹3,500 · First appeal ₹9,000 · GSTAT from ₹18,000
Notice StageASMT-10 scrutiny, DRC-01A intimation, DRC-01 show cause notice. Reply in DRC-06 with evidence and request a personal hearing. The cheapest and most effective stage to resolve a dispute.
Sections 73 · 74 · 74A73/74 govern FY 2023-24 and earlier (orders within 3 and 5 years of annual-return due date). 74A governs FY 2024-25 onward: notice within 42 months, order within 12 months, no notice under ₹1,000.
First Appeal · APL-01Within 3 months (+1 month for sufficient cause). Pre-deposit 10% of disputed tax, max ₹20 crore each CGST and SGST/IGST since 1 Nov 2024; 10% of penalty for penalty-only orders. Recovery of balance stayed.
GSTAT · APL-05Launched 24 Sep 2025; hearing cases since 16 Feb 2026. Within 3 months of first-appeal order (+up to 3 months condonable). Further 10% pre-deposit (max ₹20 crore each). Place of supply → Principal Bench.
Backlog Deadline · PassedFirst-appeal orders communicated before 1 April 2026 had to be taken to GSTAT by 30 June 2026. Whether later filings can be condoned is uncertain — seek advice immediately.
Beyond GSTATAppeal to the High Court on substantial questions of law; writ remedies for jurisdictional or natural-justice failures. High Courts increasingly expect taxpayers to use GSTAT first.
Onboarding milestones

Notice to Tribunal · the 4-phase path

Phase 1: diagnose. Phase 2: reconcile and reply. Phase 3: order and first appeal. Phase 4: GSTAT.

Phase 1Day 0-3Diagnose

What is this notice, and is it valid?

Section (73, 74 or 74A), period, limitation, quantum and the specific allegations. We check the date of communication, because every deadline runs from it.

FY 2024-25 onward: Section 74A · 42 months from annual-return due date
Phase 2Day 3-20Reply

Reconcile and reply with evidence

GSTR-1, 3B, 2B and books reconciled; each allegation answered with documents; personal hearing requested. Where tax is genuinely payable, we assess whether paying early reduces or removes penalty.

Missing the reply date invites an ex parte order
Phase 3Order + 3 monthsFirst appeal

Rectify, pay or appeal

If the order is adverse, we decide with you within weeks — not at month three. APL-01 with 10% pre-deposit (max ₹20 crore each head), which stays recovery of the balance.

3 months from communication · 1 more month only for sufficient cause
Phase 4APL-04 + 3 monthsGSTAT

Second appeal to the Tribunal

APL-05 on efiling.gstat.gov.in with a further 10% pre-deposit. The record from the reply and first appeal is what the Bench examines — which is why stage one matters most.

Backlog orders (before 1 Apr 2026) had a 30 June 2026 deadline — now passed
Every clock starts at communication Appeal periods run from the date an order is communicated to you — on the portal, by email or in person. We record it on day one and work to an internal deadline well inside the statutory one. Relying on condonation is a risk we don't take with your rights.
Start now
Avoid these traps

6 common GST dispute mistakes — and how to avoid them

#1: ignoring the notice until the order arrives. #2: not checking limitation and section. #3: counting the appeal period from the wrong date. Plus wrong pre-deposits, generic replies, and assuming the GSTAT backlog window is still open.

Mistake #1

Ignoring the notice until the order arrives

The reply stage is where evidence is placed on record and most disputes end. An unanswered notice leads to an ex parte order, and every later forum works from that thin record.

Fix: Reply fully and on time — reconciliation, documents, and a request for personal hearing. It is the cheapest and most effective stage.
Mistake #2

Not checking limitation and section

Notices for FY 2023-24 and earlier fall under Sections 73/74; from FY 2024-25, under Section 74A with a 42-month window. Notices issued late or under the wrong provision are open to challenge on that ground alone.

Fix: We check the period, the section and the dates before drafting a word on the merits.
Mistake #3

Counting the appeal period from the wrong date

The 3-month appeal period runs from communication of the order. Waiting until the last week — or miscounting — risks losing the appeal right entirely.

Fix: We record the communication date on day one and work to an internal deadline well inside the statutory one.
Mistake #4

Paying the wrong pre-deposit

Pre-deposit is 10% of the disputed tax at each appellate stage (capped at ₹20 crore each for CGST and SGST/IGST), and 10% of penalty for penalty-only orders. Under-paying can invalidate the appeal; over-paying ties up cash.

Fix: Computed precisely against the disputed amount only, with the challan and appeal filed together.
Mistake #5

Generic replies that don't answer the allegation

"We have paid all taxes correctly" is not a reply. Officers and appellate authorities decide on specific reconciliations and documents.

Fix: Allegation-by-allegation replies with reconciliations — GSTR-2B vs 3B, supplier-wise ITC, invoice trails — and a clear summary.
Mistake #6

Assuming the GSTAT backlog window is still open

For first-appeal orders communicated before 1 April 2026, the GSTAT filing deadline was 30 June 2026. Some taxpayers are only now discovering orders they never appealed.

Fix: If you have an old order, contact us immediately. Whether any delay can be condoned is uncertain and fact-specific — we will tell you plainly what options, if any, remain.
Three tiers · quoted before we start

Pick your plan

Notice reply from ₹3,500. First appeal from ₹9,000 (recommended once an order is passed). GSTAT appeal from ₹18,000. Pre-deposits and Tribunal fees go to the government, not to us.

Notice Reply
ASMT-10 · DRC-01A · DRC-01 reply
₹3,500from · + GST
₹4,130 incl. 18% GST
No government fee to reply
  • Notice diagnosis: section, period, limitation
  • Reconciliation of returns and books
  • Reply drafted with evidence index
  • Filing on the GST portal
  • Personal hearing attendance (one)
  • Payment-vs-contest recommendation
  • Fee depends on number of issues and periods
Choose Notice
GSTAT Appeal
APL-05 · GST Appellate Tribunal
₹18,000from · + GST
₹21,240 incl. 18% GST
Further 10% pre-deposit + Tribunal fee (separate)
  • Merits and record review
  • Further pre-deposit computation
  • APL-05 filing on efiling.gstat.gov.in
  • Paper book and legal submissions
  • Bench hearing representation
  • High Court options on questions of law
  • Complex or high-value matters quoted individually
Choose GSTAT

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Our approach

GST desk · 93% of notices closed at first reply

TP

The Tax Paramarsh desk

How we approach this work

"GST disputes are won on the record. The reply stage — reconciliations, documents, a clear hearing — is where most cases end, and it's what every appellate forum reads later. We check whether the notice is even valid before arguing the merits, count deadlines from the communication date, and tell clients honestly when paying is cheaper than fighting. Now that GSTAT is hearing cases, there's finally a proper second forum — but it only helps if the record below is strong."

10+ years GST practice 5,000+ businesses served 93% notices closed at first reply Replies · appeals · GSTAT
Wall of love

What business owners say about our GST litigation work

★★★★★
"Their prompt communication and easy-to-understand explanations made the entire process a breeze."
DP
Dev PokhriyalGoogle review
★★★★★
"The team at Tax Paramarsh has consistently provided accurate and timely support, ensuring my financial matters are handled with precision."
A
AyushGoogle review
★★★★★
"Wonderful service and a great coordination from office team."
SA
Shipra AroraClient review
★★★★★
"They take away the headache of the back office and I can trust them and love to work with them."
AJ
Anupama JaiswalClient review
★★★★★
"I am fully satisfied with this firm. Got best advice."
LM
Lalit MohanClient review
★★★★★
"My three years ITR was filed smoothly within an hour. The process was quick, hassle-free, and all my queries were answered patiently."
W
WangmoGoogle review
★★★★★
"Their prompt communication and easy-to-understand explanations made the entire process a breeze."
DP
Dev PokhriyalGoogle review
★★★★★
"The team at Tax Paramarsh has consistently provided accurate and timely support, ensuring my financial matters are handled with precision."
A
AyushGoogle review
★★★★★
"Wonderful service and a great coordination from office team."
SA
Shipra AroraClient review
★★★★★
"They take away the headache of the back office and I can trust them and love to work with them."
AJ
Anupama JaiswalClient review
★★★★★
"I am fully satisfied with this firm. Got best advice."
LM
Lalit MohanClient review
★★★★★
"My three years ITR was filed smoothly within an hour. The process was quick, hassle-free, and all my queries were answered patiently."
W
WangmoGoogle review
FAQ

Common questions

Straight answers on notices, sections, GSTAT, the passed backlog deadline, pre-deposits, costs, recovery and hearings. Still curious? WhatsApp us your notice.

I've received a GST notice. What should I do first?

Note the date you received it and the reply deadline, then identify the notice type: ASMT-10 (scrutiny of returns), DRC-01A (pre-show-cause intimation), DRC-01 (show cause notice) or a DRC-07 order. Check which section and period it covers. Don't ignore it, and don't pay or reply in a hurry without reconciling your returns first. Send it to us — we'll tell you what it means and what it will take.

Which section applies: 73, 74 or 74A?
  • Sections 73 and 74 continue to govern periods up to FY 2023-24. Section 73 covers non-fraud cases (order within 3 years of the annual-return due date); Section 74 covers fraud, wilful misstatement or suppression (5 years).
  • Section 74A applies from FY 2024-25: one provision for both, with notice within 42 months of the annual-return due date, order within 12 months (extendable), and no notice where the tax involved is under ₹1,000. Non-fraud penalty is 10% of tax or ₹10,000, whichever is higher.

A notice under the wrong section, or out of time, can be challenged on that basis.

Is GSTAT working now?

Yes. The GST Appellate Tribunal was launched on 24 September 2025 and began hearing cases on 16 February 2026, with a Principal Bench in New Delhi and State Benches. Appeals are filed online in APL-05 at efiling.gstat.gov.in within 3 months of the first-appeal order; the Tribunal may condone up to 3 more months for sufficient cause. Place-of-supply disputes are heard by the Principal Bench.

I have an old first-appeal order I never took further. Can I still go to GSTAT?

For first-appeal orders communicated before 1 April 2026, the Government set a special deadline of 30 June 2026 to file with GSTAT. That date has passed. Whether any delay beyond it can be condoned is uncertain and depends on the facts, and practitioners disagree on it.

Don't assume either way. Contact us immediately with the order and its communication date; we'll tell you plainly what options, if any, remain — including whether recovery has started and how to respond.

How much pre-deposit do I need to appeal?
  • First appeal (APL-01): 10% of the disputed tax, capped at ₹20 crore each for CGST and SGST/IGST (since 1 November 2024)
  • GSTAT (APL-05): a further 10% of the tax in dispute, again capped at ₹20 crore each
  • Penalty-only orders: 10% of the penalty (Finance Act 2025)

Pre-deposit is on the disputed amount — any part you accept must be paid in full. Once a valid appeal is filed with the pre-deposit, recovery of the balance is stayed. Our calculator on this page works the numbers out.

What do your services cost?
  • Notice Reply: from ₹3,500 — scrutiny, intimation or show cause notice
  • First Appeal: from ₹9,000 — APL-01 with hearing
  • GSTAT Appeal: from ₹18,000 — APL-05 with Bench hearing

Fees depend on the number of issues, periods and hearings, and are quoted before we start. Pre-deposits and Tribunal fees are paid to the government, not to us.

Should I just pay instead of fighting?

Sometimes, yes. If the demand is genuinely correct, paying tax and interest early — before the notice, or within the period allowed after it — can reduce or remove the penalty in non-fraud cases. If the amount is small and the grounds weak, the pre-deposit and costs of an appeal may exceed what you could save. We give you that comparison honestly before you decide.

Can you guarantee the notice will be dropped?

No. Outcomes depend on the facts, the law and the officer or Bench deciding. What we can promise is a reply or appeal that answers every allegation with evidence, meets every deadline and preserves your rights at the next stage. Our firm has closed 93% of notices at the first reply — but each case is decided on its own record.

How long do I have to appeal?
  • First appeal: 3 months from communication of the order; 1 more month if the authority accepts sufficient cause
  • GSTAT: 3 months from communication of the first-appeal order; the Tribunal may condone up to 3 more months
  • Backlog (orders before 1 April 2026): the special GSTAT deadline was 30 June 2026 — now passed

Always count from the date of communication, and don't plan to use the condonation period.

What about the Section 128A waiver?

Section 128A offered a conditional waiver of interest and penalty for non-fraud (Section 73) demands for FY 2017-18 to 2019-20, where the full tax was paid by 31 March 2025. That payment window has closed. If you paid in time, the waiver can still be claimed through the prescribed procedure — we can check whether it was applied correctly to your case.

The department has started recovery. What can I do?

If you are within the appeal period, filing a valid appeal with the required pre-deposit stays recovery of the balance. CBIC has clarified that where the pre-deposit is not made or, with GSTAT now operational, the appeal is not filed in time, recovery can proceed. Act quickly: we check the order, the timeline and the pre-deposit, and file.

Do I have to attend hearings myself?

Usually not. As your authorised representative we attend personal hearings and Bench hearings, present reconciliations and file written submissions. We may need you to confirm facts or sign documents, and in some matters your presence helps. We tell you in advance.

✦ Received a GST notice or order?

Send it to us today.

WhatsApp a photo of the notice or order and the date you received it. Free 30-minute review: what it means, whether it's valid, your deadline and whether to reply, pay or appeal. Notice Reply from ₹3,500. First Appeal from ₹9,000. GSTAT from ₹18,000.

Limitation checked first
Deadlines from communication
Pre-deposit computed
Honest pay-or-appeal view