FORM GST APL-03 - Commissioner-directed departmental first application
A Commissioner’s review identifies a legal error in an adjudication order; this is not a taxpayer appeal.
Responsible actor: The subordinate officer specifically directed by the Commissioner. Provision: Section 107(2)/(3); rule 109; rule 89(4) refund Net ITC.
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
May 2026 refund 120000 includes capital-goods credit 18000. Commissioner directs a limited departmental challenge; corrected eligible refund 102000. Every value and authorisation branch is fictional.
1–5. Authorised officer and order
| 1. Officer /designation | N.Prakash /Assistant Commissioner; fictional unsigned |
|---|---|
| Jurisdiction /State-Centre | Illustration Bengaluru /Centre /Karnataka |
| Commissioner direction | ILLUSTRATION-DIRECTION-B /20 August 2026; actual authorisation must be uploaded in a real case |
| 2. GSTIN | 29AABCA0000A1ZT |
| 3. Order/date | ILLUSTRATION-RFD-B /15 July 2026 |
| 4. Passing officer/address | P.Shah, Deputy Commissioner /Illustration CGST Bengaluru560001 |
| 5. Communication | 15 July 2026; uploaded on portal |
6–9. Dispute and grounds
| 6(i). Brief issue | Capital-goods credit included in refund Net ITC contrary to rule 89(4). |
|---|---|
| 6(ii). Goods/services | Zero-rated stationery exports without payment; classification and export status not in dispute. |
| 6(iii). Period | May 2026; refund claim 10 June 2026 |
| 7. Facts | Refund120000 comprises otherwise eligible 102000 and capital-goods credit 18000; only the latter is challenged. |
| 8. Grounds | Rule 89(4) Net ITC covers eligible inputs/input services, not capital goods. Seek correction of the erroneous sanction component, with due process for any resulting recovery. |
| 9. Prayer | Modify sanctioned refund to 102000, reducing 9000 under each CGST/SGST head; do not invent a separate tax/interest/penalty demand in this application. |
6(iv). Disputed refund components, INR
| Particular | CGST | SGST/UTGST | IGST | Cess | Total |
|---|---|---|---|---|---|
| Refund /tax-credit component | 9000 | 9000 | 0 | 0 | 18000 |
| Interest | 0 | 0 | 0 | 0 | 0 |
| Penalty | 0 | 0 | 0 | 0 | 0 |
| Fees | 0 | 0 | 0 | 0 | 0 |
| Others | 0 | 0 | 0 | 0 | 0 |
10. Refund created and disputed, INR
| Component | CGST sanctioned | SGST sanctioned | IGST | Cess | Total sanctioned | Total disputed |
|---|---|---|---|---|---|---|
| Refund | 60000 | 60000 | 0 | 0 | 120000 | 18000 |
| Interest | 0 | 0 | 0 | 0 | 0 | 0 |
| Penalty | 0 | 0 | 0 | 0 | 0 | 0 |
| Fees | 0 | 0 | 0 | 0 | 0 | 0 |
| Others | 0 | 0 | 0 | 0 | 0 | 0 |
Filing period and execution
| Place/date/name/status/signature and declaration | File1 September 2026, within six calendar months ending 15 January 2027. This Commissioner-directed 107(2) application is not subject to the taxpayer 107(6) deposit gate. Place:Bengaluru; date 1 September 2026; officer:N.Prakash, Assistant Commissioner, Illustration Bengaluru; signature:not executed. |
|---|
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
APL03 is a Commissioner-directed departmental application under 107(2), not the taxpayer’s APL01. The statutory period is six months from communication with only the lawful further one-month condonation on sufficient cause. Rule 109 uses current final acknowledgement/copy rules, with manual route only in the specified circumstances. The refund correction is 18000, not a demand for the full 120000 sanction.
Primary source and exact locator
Official notified form source: Official1 January 2022 forms compilation, actual FORM GST APL-03, PDF pages 343–344; source/version conflicts expressly corrected by current Act/rules..
CGST Act and government-hosted Act and Rules compilation - Section 107(2)/(3); rule 109; rule 89(4) refund Net ITC. Source and example revision: 21 October 2026.
Questions answered by this example
Who prepares or issues this form?
The subordinate officer specifically directed by the Commissioner. A Commissioner’s review identifies a legal error in an adjudication order; this is not a taxpayer appeal.
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..