GST Appeal Format APL-01 — Grounds of Appeal u/s 107
GROUNDS OF APPEAL AND STATEMENT OF FACTS
[Annexures to FORM GST APL-01 — Appeal to the Appellate Authority under section 107 of the CGST Act, 2017 read with Rule 108]
Before the {{appellate_authority}}
Appellant: {{client_name}}
GSTIN: {{client_gstin}}
Address: {{client_address}}
Order appealed against: Order under section {{order_section}} of the CGST Act, 2017 passed by the ____________ [designation of adjudicating authority], vide {{order_ref}} dated {{order_date}}, for the period {{tax_period}}
Disputed tax: ₹ {{disputed_tax}}
PART A — STATEMENT OF FACTS
1. The appellant is ____________ [constitution and nature of business in one or two sentences], registered under the CGST Act, 2017 with GSTIN {{client_gstin}}.
2. The chronology of the proceeding culminating in the impugned order is set out below:
| Date | Event | Reference |
|---|
| ____________ | Intimation in FORM GST DRC-01A / scrutiny notice in ASMT-10 (if any) | ____________ |
| ____________ | Show cause notice in FORM GST DRC-01 issued | ____________ |
| ____________ | Reply to SCN filed; personal hearing attended on ____________ | ____________ |
| {{order_date}} | Impugned order passed; summary uploaded in FORM GST DRC-07 | {{order_ref}} |
3. By the impugned order, the adjudicating authority has confirmed a demand of tax of ₹ {{disputed_tax}} together with interest and penalty, on account of ____________ [state each head of demand factually, with the amount — no argument here].
4. The appellant had, during adjudication, furnished ____________ [list the key evidence and reconciliations filed]. The demand has been confirmed ____________ [state factually what the order did or failed to do — e.g. 'without dealing with the reconciliation on record' / 'by invoking section 74 without any particularised allegation of suppression'].
5. Aggrieved, the appellant prefers this appeal within the period of three months from the date of communication of the order provided in section 107(1). The mandatory pre-deposit under section 107(6) has been made as per the computation in Part C below.
PART B — GROUNDS OF APPEAL
1. On the facts and in the circumstances of the case and in law, the impugned order is bad in law and void ab initio, ____________ [jurisdictional / procedural ground, if any — e.g. 'having been passed without granting the personal hearing mandated by section 75(4)' or 'the SCN and the order having travelled beyond each other'; omit if none exists].
2. On the facts and in the circumstances of the case and in law, the adjudicating authority erred in confirming a demand of ₹ ____________ on account of ____________, without appreciating that ____________ [one head of demand per ground, stated as a concise assertion of error].
3. Without prejudice to Ground 2, the adjudicating authority erred in ____________ [alternative / quantum ground — e.g. 'not allowing credit of the amounts already paid through DRC-03' or 'computing the demand on the gross figure without the cum-tax benefit'].
4. On the facts and in the circumstances of the case and in law, the adjudicating authority erred in invoking section 74 and levying penalty thereunder, the ingredients of fraud, wilful misstatement or suppression having been neither alleged with particulars nor established.
5. The levy of interest and penalty is consequential and excessive, and the appellant denies liability thereto.
6. The appellant craves leave to add, alter, amend or withdraw any of the above grounds of appeal at or before the time of hearing.
PART C — PRE-DEPOSIT COMPUTATION (Section 107(6))
| Particulars | Amount (₹) |
|---|
| Tax admitted (paid in full — with interest, fine, fee and penalty arising therefrom) | ____________ |
| Tax in dispute | {{disputed_tax}} |
| Pre-deposit @ 10% of the disputed tax | ____________ |
| Paid vide (electronic cash / credit ledger debit, ARN and date) | ____________ |
- Pre-deposit note: section 107(6) requires payment in full of the admitted amount plus 10% of the remaining tax in dispute, subject to a cap of ₹20 crore under the CGST Act (and ₹20 crore under the SGST/UTGST Act) — the cap having been reduced from ₹25 crore by the Finance (No. 2) Act, 2024, with effect from 1 November 2024. On making the pre-deposit, recovery of the balance is deemed stayed under section 107(7).
- Pre-deposit note: for orders involving only penalty (no tax demand), the Finance Act, 2025 introduced a separate pre-deposit of a percentage of the penalty in dispute with effect from 1 April 2025 — verify the current text of section 107(6) before computing the deposit in a penalty-only appeal.
- Limitation note: the appeal lies within three months of communication of the order (section 107(1)); the Appellate Authority may condone a delay of up to one further month on sufficient cause (section 107(4)). File the condonation application with the appeal itself if the three months have run out.
PRAYER
The appellant prays that the impugned order be set aside and the demand of tax, interest and penalty be quashed; in the alternative, that the demand be restricted as per the grounds above; and that such further relief be granted as the facts and circumstances of the case may warrant.
VERIFICATION
I, ____________, the authorised signatory of the appellant, do hereby declare that what is stated above is true to the best of my information and belief.
Place: __________________
Date: 31 July 2026
For {{client_name}}
_______________________________
Authorised Signatory
