Rule 110 - Appeal to the Appellate Tribunal
CGST Rules, 2017
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Source control: The text/status on this page is tied to the official source gateway and the Phase 1 legal-review register. Open official source.
Finin2min Summary - Rule in 2 Minutes
Current APL-05 GSTAT electronic filing, APL-02A provisional/final acknowledgement and revised minimum/ maximum fee structure effective 22 September 2025.
Exact operative text
110. Appeal to the Appellate Tribunal.-(1) An appeal under section 112(1) shall be filed electronically in
FORM GST APL-05 with relevant documents and provisional acknowledgement in Part A of FORM GST
APL-02A shall issue immediately. (2) Cross-objections under section 112(5) shall be filed electronically in
FORM GST APL-06. (3) The appeal and cross-objections shall be signed under rule 26. (4) Where the
appealed order is on the portal, final acknowledgement in Part B of FORM GST APL-02A issues after
removal of defects and the provisional-acknowledgement date is the filing date. If the order is not on the
portal, a self-certified copy must be submitted/uploaded within seven days; later submission makes that later
date the filing date. An appeal is treated as filed only when final acknowledgement indicating the appeal
number is issued. (5) Appeal/restoration fee is one thousand rupees per one lakh rupees of tax, ITC,
difference, fine, fee or penalty involved, subject to a minimum of five thousand rupees and maximum of
twenty-five thousand rupees; an appeal without monetary demand carries fee of five thousand rupees. (6)
No fee applies to a rectification application under section 112(10).
Paragraph-wise decode
Current APL-05 GSTAT electronic filing, APL-02A provisional/final acknowledgement and revised minimum/ maximum fee structure effective 22 September 2025.
Section-Rule-Form-Notification bridge
No direct Rule certified in Phase 1. Check notifications, circulars, forms and corresponding State law.
The mapping is a legal concordance, not a round-robin related-link list. It is limited to instruments certified in this phase.
Practical example
Apply the rule to the relevant form, period, portal event and evidence trail before reaching a compliance conclusion.
Professional alert
Verify the latest official active Rule page, amending Gazette and portal version before filing or advising.
Implementation checklist
- Fix the transaction, taxable period and jurisdiction.
- Read every subsection, proviso, explanation and omission marker.
- Open the mapped Rule, form, notification and circular.
- Test State/UT variation and portal version.
- Preserve evidence, approvals, working papers and acknowledgements.
- Record the conclusion, assumptions, source date and reviewer.
Evidence and retention checklist
- Contract, purchase order, invoice or underlying transaction document.
- Registration, return, ledger, challan and portal acknowledgement.
- Official Act/Rule/notification version used and effective date.
- Internal tax position paper, computation and management approval.
- Correspondence, notices, replies, orders and appeal papers where applicable.
Practical Q&A
- What does rule 110 regulate?
- It regulates appeal to the appellate tribunal. Read the exact text, conditions, exceptions and transaction date together.
- Which subordinate law should be checked?
- No direct CGST Rule has been certified in this phase. Notifications, circulars, forms and the corresponding SGST/UTGST layer may also apply.
- What evidence should be retained?
- Preserve the contract or transaction record, invoice or form, portal acknowledgement, payment/ledger evidence, correspondence, legal working and the official source version used.
- Can portal behaviour override the statute?
- No. Portal functionality is operational evidence; legal entitlement and liability remain controlled by the Act, Rules, notifications and binding decisions.