30 June 2026
GSTAT backlog deadline
Pre-April-2026 orders - file or lose the right forever
GSTAT backlog deadline: 30 June 2026
GST Notice & Litigation Support - From First Notice to Tribunal, Fought Properly
Received DRC-01C, ASMT-10, REG-17, RFD-08, a show cause notice, or an adverse GST order? We diagnose the deadline, build the evidence record, compute pre-deposit, and file replies or appeals before rights are lost.
- GSTAT APL-05 filing before the 30 June 2026 backlog deadline
- DRC-01, DRC-01C, ASMT-10, REG-17 and RFD-08 replies
- First appeal under Section 107 and tribunal appeal under Section 112
- Pre-deposit computation and DRC-03 support
- Hearing representation and recovery defence
3 months
Normal appeal window
For orders communicated from 1 April 2026 onward
10%
GSTAT pre-deposit
Of remaining disputed tax, via DRC-03, subject to statutory caps
4 lakh+
Orders in the backlog
Eight years of appeals, one open window
Trusted for GST disputes
Support for founders, sellers and finance teams
Built for urgent GST dispute response
Backlog deadline
0 Jun
GSTAT appeals for pre-April-2026 orders must be filed before the cliff date.
Normal limitation
0mo
Fresh appeal windows are short, so notice and order diagnosis must start immediately.
Notice types handled
0+
From DRC-01C mismatch notices to tribunal appeal bundles and recovery matters.
What is GST notice and litigation support?
GST litigation support covers the structured defence of a taxpayer through the GST dispute ladder - replying to departmental notices, contesting demand orders before the First Appellate Authority under Section 107, and filing second appeals before the GST Appellate Tribunal (GSTAT) under Section 112 of the CGST Act.
The 2026 reality is that many notices are now system-driven: DRC-01C mismatches, e-invoice gaps, return scrutiny, ECRS flags, refund SCNs and cancellation show-cause notices. The reply must reconcile data, not merely deny the allegation.
The GSTAT vacuum has also ended after years without a functioning tribunal. Backlog orders communicated before 1 April 2026 face a 30 June 2026 filing cliff, while newer orders follow the normal 3-month limitation.
Sub-services
Which GST dispute support do you need?
Each notice, appeal, or recovery action has its own form, section, evidence standard, and deadline.
GST Notice Reply
DRC-01C mismatches, ASMT-10 scrutiny, REG-03 queries and RFD-08 refund SCNs each need form-specific replies. We diagnose the notice, prepare an evidence-backed response, and file inside the window.
Show Cause Notice Defence
A DRC-01 means the department is committing to a legal theory. We attack jurisdiction, limitation, computation and evidence, while building the record needed if the matter moves to appeal.
First Appeal Filing (APL-01)
For adverse Section 73 or 74 orders, we file before the Commissioner (Appeals) under Section 107 with pre-deposit computed correctly and grounds drafted for the dispute record.
GSTAT Appeal Filing (APL-05)
The tribunal is open. We compute Section 112(8) pre-deposit, assemble the e-filing bundle, and file backlog orders before 30 June 2026 where applicable.
Departmental Audit & Scrutiny Support
ADT-01 audits and ASMT-10 scrutiny run on your data trail. We prepare reconciliations across books, GSTR-3B, GSTR-1, GSTR-2B and e-invoice records.
Demand & Recovery Defence
For DRC-07 demands, bank attachment threats and recovery proceedings, we move for stays, negotiate instalments and keep the business running while the dispute is fought.
Real dispute paths
Every GST dispute has a deadline, a risk, and a record to build
FAA order from 2023 sitting unappealed
Right dies on 30 June 2026
APL-05 filed in days
DRC-01C auto-notice
Mismatch is real but explainable
Reconciliation reply, demand dropped
SCN under Section 74 alleging fraud
100% penalty exposure
Full defence on merits and limitation
Bank account attachment notice
Operations threatened
Stay obtained, instalments negotiated
Tribunal era
The tribunal era begins
The GSTAT vacuum has ended. Appeals that waited for years now need disciplined limitation tracking, pre-deposit computation, and a complete electronic filing bundle.
GSTAT is operational under Section 109, creating the long-awaited second appellate tier.
Backlog appeals face a 30 June 2026 cliff; fresh orders move under the normal 3-month limitation.
Pre-deposit math matters: 10% at GSTAT stage over the earlier first appeal deposit, paid via DRC-03.
APL-05 filing is bundle-driven: grounds, authorization, order copies, challans, and PDFs must be ready before filing.
Process
How we handle GST notices, appeals and tribunal filings
- 1
Notice or order diagnosis
Step 1We identify the form, section, deadline, monetary exposure, pre-deposit and available remedies.
- 2
Strategy call
Step 2We decide whether to reply, appeal, settle, seek stay, or prepare for representation with the commercial math visible.
- 3
Evidence and reconciliation build
Step 3Returns, ledgers, invoices, e-way bills, e-invoice data and books are reconciled into officer-ready evidence.
- 4
Drafting by GST practitioners
Step 4Replies and appeal grounds are drafted for the legal issue, facts, limitation and computation.
- 5
Filing with pre-deposit where needed
Step 5We file notice replies, APL-01 or APL-05 and support DRC-03 pre-deposit payment where applicable.
- 6
Representation and follow-through
Step 6We support hearings, stay requests, recovery management, order review and next-step decisions.
Documents
Documents needed for notice reply or appeal
GST dispute filings succeed when the bundle is complete, readable and tied to the exact allegation.
- Notice copy and ARN
- Relevant GST returns
- Books extracts and ledgers
- Mismatch reconciliation statements
- Order-in-original
- Order-in-appeal, if any
- Payment challans
- Pre-deposit DRC-03 details
- Complete certified appeal bundle
- Authorization and statement of facts
- All PDFs under portal limits and readable at filing time
Document requirements can vary by entity type and state. Our team shares a final checklist after reviewing your case.
Avoid procedural failure
Why GST disputes are lost - and how we protect the record
Many GST matters fail before merits are heard because deadlines, pre-deposit or filing discipline were missed.
The risk
Deadline missed
Limitation can extinguish the right to appeal, especially for GSTAT backlog matters.
How we handle it
Every matter is calendared from day one with the forum, form, limitation date and fallback route mapped.
The risk
Boilerplate replies
Generic replies fail the officer's checklist and often escalate notices into demand orders.
How we handle it
We draft against the exact allegation, data mismatch, evidence and legal test.
The risk
Pre-deposit miscomputed
Wrong pre-deposit can create admission defects or avoidable objections.
How we handle it
Section 107 and 112 pre-deposit math is verified before filing and DRC-03 payment.
The risk
Incomplete GSTAT bundle
Tribunal e-filing depends on a complete bundle; missing documents create defects and delay.
How we handle it
We prepare the appeal bundle before APL-05 filing, including orders, grounds, authorizations and annexures.
The risk
Fighting everything
Some disputes cost more to fight than the commercial exposure justifies.
How we handle it
Every case receives a settle-versus-fight analysis before strategy is locked.
FAQ
GST notice and appeal questions, answered
Clear answers for taxpayers facing notices, scrutiny, recovery, first appeal or GSTAT filing decisions.
Fast answersExpert support
- GSTAT is the Goods and Services Tax Appellate Tribunal, the second appellate forum under Section 112 of the CGST Act after the First Appellate Authority and before the High Court.
- For appellate orders communicated before 1 April 2026, the backlog appeal window closes on 30 June 2026. Missing that date can permanently extinguish the right to file at GSTAT.
- The GSTAT pre-deposit under Section 112(8) is 10% of the remaining disputed tax, over and above the first appeal pre-deposit, subject to statutory caps and paid through DRC-03.
- Form APL-05 is the electronic form used to file a second appeal before GSTAT. The appeal bundle, grounds, authorization, and supporting documents must be prepared before filing.
- DRC-01C is a GST portal notice for mismatch between outward supplies reported in GSTR-1 and tax paid through GSTR-3B. It needs a reconciliation-backed explanation or payment response.
- A GST show cause notice reply should address jurisdiction, facts, limitation, computation, evidence, and legal grounds. A boilerplate reply can convert a notice into a demand order.
- A first GST appeal under Section 107 is generally filed within 3 months from communication of the order, with pre-deposit and grounds filed through Form APL-01.
- Some first appeal delays may be condoned within the statutory condonation window, but tribunal backlog deadlines and limitation issues must be assessed case by case immediately.
- ASMT-10 is a scrutiny notice where the department flags discrepancies in returns or data. It should be answered with reconciliations, documents, and a clear explanation.
- Ignoring a GST notice can lead to demand orders, registration cancellation, recovery proceedings, bank attachment, interest, penalty, or loss of appeal rights.
- Recovery can often be managed through statutory pre-deposit, stay applications, instalment requests, or representation, depending on the stage and facts of the dispute.
- GST notices and appeals benefit from a practitioner who understands returns, reconciliations, limitation, pre-deposit, and the dispute record that higher forums will review.
Related services
Prevent, respond and recover
Notice defence is stronger when filings, registrations and refunds are clean before the department asks.
Prevent the Notice
Registration Disputes
Refund Disputes
The tribunal waited eight years. Your deadline won't.
If you have a GST notice, demand order, first appeal order or recovery threat, get the deadline diagnosed before the window closes.
GSTAT backlog closes 30 June 2026 for eligible pre-April-2026 orders.