FORM GST APL-01 - Taxpayer first appeal with tax-only deposit reconciled
An appealable adjudication order has been communicated; this is a first appeal, not a tribunal application.
Responsible actor: The aggrieved taxpayer, through an eligible authorised representative. Provision: Section 107(1),(4),(6),(11); rule 108.
Official source and completed example
Download official blank source extract PDF Download completed fictional sample PDF
The sample is a flowed model of the prescribed fields and selected paragraphs, not an official issued PDF. Names, references and facts are fictional. It contains no signature, stamp, DSC or simulated approval.
Current operative Act/rules checked 21 October 2026. Historical2022 extracts are retained as source evidence; current amendments stated in this guide control. Fictional unsigned completed model, including expressly hypothetical later case events.
Worked facts and completed entries
Independent credit Branch A: an April 2023 invoice appears in April GSTR2B; goods are received 12 May 2023, credit 100000 CGST+100000 SGST is first availed and utilised 20 June 2023 in the May return, with every section 16 condition otherwise satisfied. A15 July 2026 section 73 order, communicated/uploaded that day, wrongly rejects the credit solely because the invoice does not reappear in May GSTR2B. It demands tax 200000, assumed interest 110564 and penalty 20000, total 330564. The interest computation in the disputed order is 1121 days at 18% on 100000 per head, rounded 55282 per head; recording it does not admit it is payable. Aster disputes everything, pays 20000 pre-deposit against disputed tax only and files 1 September 2026. In Branch A the Appellate Authority annuls the demand 30 September after 20 September hearing.
1–8. Appellant and impugned order
| 1. GSTIN | 29AABCA0000A1ZT |
|---|---|
| 2. Legal name | Aster Learning Supplies Private Limited (fictional) |
| 3. Trade name | Aster Learning Supplies |
| 4. Address | 12 Learning Park, Bengaluru, Karnataka 560001 (fictional) |
| 5. Order number/date | ILLUSTRATION-TAX-A /15 July 2026 |
| 6. Passing officer/address | P.Shah, Deputy Commissioner /Illustration CGST office, Bengaluru560001; fictional |
| 7. Communication | 15 July 2026; order uploaded same day |
| 8. Representative | Meera Rao, full-time employee/director, authorised in this fictional case under section 116(2)(a); no actual professional enrolment claimed /meera@aster.example.invalid /EDU-MEERA-PHONE (non-routable) |
9–13. Dispute, facts, grounds and prayer
| 9(i). Brief issue | Credit denied merely because an April GSTR2B invoice was not repeated in May, when goods were received and credit first claimed. |
|---|---|
| 9(ii). Goods/classification | Business inventory, stationery inputs; classification/rate is not in dispute, no fabricated HSN determination. |
| 9(iii). Period | 1 May–31 May 2023; relevant April invoice disclosed |
| 9(v). Market value seized | Not applicable:no seizure |
| 10. Personal hearing | Yes; requested |
| 11. Facts | Independent credit Branch A: an April 2023 invoice appears in April GSTR2B; goods are received 12 May 2023, credit 100000 CGST+100000 SGST is first availed and utilised 20 June 2023 in the May return, with every section 16 condition otherwise satisfied. A15 July 2026 section 73 order, communicated/uploaded that day, wrongly rejects the credit solely because the invoice does not reappear in May GSTR2B. It demands tax 200000, assumed interest 110564 and penalty 20000, total 330564. The interest computation in the disputed order is 1121 days at 18% on 100000 per head, rounded 55282 per head; recording it does not admit it is payable. Aster disputes everything, pays 20000 pre-deposit against disputed tax only and files 1 September 2026. In Branch A the Appellate Authority annuls the demand 30 September after 20 September hearing. |
| 12. Grounds | Section 16(2)(aa) invoice communication and 16(2)(b) receipt are satisfied by April GSTR2B and May goods receipt; no legal requirement to repeat the same invoice in each later 2B. All other credit conditions are assumed proved. Consequential section 50(3) interest and 73 penalty fall if credit is lawful. |
| 13. Prayer | Annul the tax, interest and penalty demand after examining existing evidence; grant consequential lawful relief. |
9(iv). Amount under dispute, INR
| Particular | CGST | SGST/UTGST | IGST | Cess | Total |
|---|---|---|---|---|---|
| Tax | 100000 | 100000 | 0 | 0 | 200000 |
| Interest | 55282 | 55282 | 0 | 0 | 110564 |
| Penalty | 10000 | 10000 | 0 | 0 | 20000 |
| Fees | 0 | 0 | 0 | 0 | 0 |
| Others | 0 | 0 | 0 | 0 | 0 |
14. Created /admitted /disputed demand, INR
| Particular /head | Determined/created | Admitted | Disputed |
|---|---|---|---|
| Tax /CGST | 100000 | 0 | 100000 |
| Tax /SGST | 100000 | 0 | 100000 |
| Tax /IGST | 0 | 0 | 0 |
| Tax /Cess | 0 | 0 | 0 |
| Tax /Total | 200000 | 0 | 200000 |
| Interest /CGST | 55282 | 0 | 55282 |
| Interest /SGST | 55282 | 0 | 55282 |
| Interest /IGST | 0 | 0 | 0 |
| Interest /Cess | 0 | 0 | 0 |
| Interest /Total | 110564 | 0 | 110564 |
| Penalty /CGST | 10000 | 0 | 10000 |
| Penalty /SGST | 10000 | 0 | 10000 |
| Penalty /IGST | 0 | 0 | 0 |
| Penalty /Cess | 0 | 0 | 0 |
| Penalty /Total | 20000 | 0 | 20000 |
| Fees /CGST | 0 | 0 | 0 |
| Fees /SGST | 0 | 0 | 0 |
| Fees /IGST | 0 | 0 | 0 |
| Fees /Cess | 0 | 0 | 0 |
| Fees /Total | 0 | 0 | 0 |
| Others /CGST | 0 | 0 | 0 |
| Others /SGST | 0 | 0 | 0 |
| Others /IGST | 0 | 0 | 0 |
| Others /Cess | 0 | 0 | 0 |
| Others /Total | 0 | 0 | 0 |
15(a). Required admitted amount and deposit, INR
| Particular | CGST | SGST/UTGST | IGST | Cess | Total |
|---|---|---|---|---|---|
| Admitted tax | 0 | 0 | 0 | 0 | 0 |
| Admitted interest | 0 | 0 | 0 | 0 | 0 |
| Admitted penalty | 0 | 0 | 0 | 0 | 0 |
| Admitted fees | 0 | 0 | 0 | 0 | 0 |
| Admitted others | 0 | 0 | 0 | 0 | 0 |
| 10% disputed-tax pre-deposit | 10000 | 10000 | 0 | 0 | 20000 |
| Penalty-only-order deposit branch — not selected | 0 | 0 | 0 | 0 | 0 |
15(b). Payment by head and ledger, INR
| Head | Required | Cash paid | Credit paid | Debit reference |
|---|---|---|---|---|
| CGST | 10000 | 10000 | 0 | ILLUSTRATION-APL-A-C |
| SGST | 10000 | 10000 | 0 | ILLUSTRATION-APL-A-S |
| IGST | 0 | 0 | 0 | Not applicable |
| Cess | 0 | 0 | 0 | Not applicable |
15(c). Non-tax payments
Interest, penalty, late fee and other admitted amounts payable/paid:0 in every CGST/SGST/IGST/cess cell; debit entries:not applicable. Disputed interest/penalty are not part of the ordinary disputed-tax deposit base.
16–18. Time limit and place of supply
| 16. After prescribed period | No:1 September within three calendar months from 15 July communication; ordinary last date 15 October 2026. |
|---|---|
| 17(a)/(b). Delay/reason | Not applicable:no delay; no condonation claimed. Historical printed item 17 self-reference is read with preceding delay question 16. |
| 18. IGST place-of-supply admitted-demand table | Not applicable:IGST tax/interest/penalty/others/total 0; no admitted IGST demand or place-of-supply issue |
Verification /execution
The stated facts and records are affirmed solely within this fictional teaching scenario; nothing is concealed. Place:Bengaluru. Date:1 September 2026. Name/status:Meera Rao, full-time employee/director, authorised in this fictional case under section 116(2)(a); no actual professional enrolment claimed. Signature:not executed. No actual DSC, signature, acknowledgement, judicial officer or official approval is simulated.
How this form moves the matter forward
- Identify the actual authority, order, communication date and statutory appeal route. An appeal form is not an appeal against every administrative step.
- Reconcile all tax-head demand/refund columns, admitted amounts, deposits, authorisation and evidence. Use the current operative Act even where the preserved historical blank is older.
- File on the applicable authenticated portal, cure actual defects and obtain the final acknowledgement. Preserve the reasoned order and service/hearing history; this fictional PDF is not an issued acknowledgement or filing.
Evidence supporting these entries
- Actual impugned order and communication/upload evidence; complete earlier proceeding and hearing record.
- Invoice, GSTR2B, receipt, credit utilisation or refund computation that supports the selected issue; no invented actual portal document.
- Authority to represent/file; reconciled deposit/payment and filing acknowledgement, with every amount matched to the correct statutory stage.
Additional primary authority: CGST Act as on 11 June 2026: sections 16,50,73,107 at PDF pages 18–21,48–49,61–63,85–87; sections 109/112–120 at pages 87–97. Current20-crore CGST cap and penalty-only 10% provisions, not older form caps..
Additional primary authority: April 2026 consolidated CGST rules 108–115 at PDF pages 312–319; rules 89(4),110(5),112 and 26 for the selected matters..
Additional primary authority: Notification 26/2022-Central Tax,26 December 2022: paragraphs 13–15 PDF pages 5–6 (rules 108/109/109C); paragraphs 23–24 pages 13–14 (APL02 header and actual APL01/03W)..
Additional primary authority: Notification 13/2025-Central Tax,17 September 2025 effective 22 September 2025: English paragraphs 5–8 pages 49–50; paragraphs 11–15 pages 59–82, current APL02A/04A/05/06/07..
Additional primary authority: Notification 38/2023-Central Tax,4 August 2023 paragraphs 16–17 PDF pages 5–6: narrowly defined manual first-appeal/application routes..
Period and legal consequences
The old blank’s25-crore CGST cap is outdated:current 107(6) uses 20 crore. Ordinary deposit is 10% of disputed tax, not 10% of the entire demand; admitted components must be paid in full. From 1 October 2025 the penalty-only proviso covers any penalty-only order at 10%, replacing the old 129-only 25% gate. Portal-uploaded order needs no universal certified-copy resubmission; otherwise a self-certified copy within seven days preserves provisional filing date, and late copy shifts it. Ordinary time limit is three calendar months, with at most one further month on sufficient cause. The Appellate Authority may confirm/modify/annul but cannot remand under 107(11).
Primary source and exact locator
Official notified form source: Official1 January 2022 forms compilation, actual FORM GST APL-01, PDF pages 337–341; source/version conflicts expressly corrected by current Act/rules..
CGST Act and government-hosted Act and Rules compilation - Section 107(1),(4),(6),(11); rule 108. Source and example revision: 21 October 2026.
Questions answered by this example
Who prepares or issues this form?
The aggrieved taxpayer, through an eligible authorised representative. An appealable adjudication order has been communicated; this is a first appeal, not a tribunal application.
Can this sample be filed or treated as an issued document?
No. It is a completed fictional teaching example. Use the notified form and the authenticated portal/proceeding record for an actual matter. The example contains no executed signature or official approval.
What must reconcile before the next step?
Actual impugned order and communication/upload evidence; complete earlier proceeding and hearing record.; Invoice, GSTR2B, receipt, credit utilisation or refund computation that supports the selected issue; no invented actual portal document.; Authority to represent/file; reconciled deposit/payment and filing acknowledgement, with every amount matched to the correct statutory stage..