FORM GST APL-06 - Cross-objections with 45-day notice clock and two annexures
A party cross-objects against part of the same impugned order, within 45 days of notice receipt.
Responsible actor: The respondent receiving notice of another party’s tribunal appeal/application. Provision: Section 112(5)/(6); rules 110(2)/111(2); current APL06.
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 refund Branch D: May 2026 zero-rated-without-payment refund claim 120000000 comprises 102000000 otherwise eligible credit,6000000 disputed freight-service credit reflected in April GSTR2B and received in May, and 12000000 capital-goods credit. Original15 July 2026 order allows 102000000. First appeal 30 September allows the 6000000 freight component but rejects capital goods, determining 108000000. Commissioner directs a departmental tribunal appeal 5 October seeking restoration of 102000000 (6000000 disputed refund). Department files 10 October; notice reaches Aster12 October. Aster cross-objects 20 October seeking the additional 12000000 capital-goods component. That capital-goods contention is the fictional litigant’s argument, not the guide’s statement of entitlement: rule 89(4) Net ITC excludes capital goods. The departmental amount 60 lakh exceeds the Central20-lakh tribunal monetary threshold; no exception is invented.
1–6. Case and cross-objector
| 1. Appeal number/filed | ILLUSTRATION-GSTAT-D /10 October 2026 |
|---|---|
| 2. Filing by/GSTIN/name | 29AABCA0000A1ZT /Aster Learning Supplies Private Limited (fictional) |
| 2. Email/phone/address | meera@aster.example.invalid /EDU-MEERA-PHONE (non-routable) /12 Learning Park, Bengaluru, Karnataka 560001 (fictional) |
| 2. Department officer/designation/office/email/contact | Not applicable:taxpayer cross-objector; all departmental-only fields inapplicable |
| 3. A Aorder/date | ILLUSTRATION-APL04-D /30 September 2026 |
| 4. Designation/jurisdiction/passed by | Joint Commissioner (Appeals) /Illustration Bengaluru /S.Kumar; fictional |
| 5. Communication | 30 September 2026 |
| 6. Representative/email/contact | 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) |
7(ii). Additional refund under cross-objection, INR
| Particular | CGST | SGST/UTGST | IGST | Cess | Total |
|---|---|---|---|---|---|
| Tax/credit-refund dispute (not additional tax demand) | 6000000 | 6000000 | 0 | 0 | 12000000 |
| Interest | 0 | 0 | 0 | 0 | 0 |
| Penalty | 0 | 0 | 0 | 0 | 0 |
| Fees | 0 | 0 | 0 | 0 | 0 |
| Others | 0 | 0 | 0 | 0 | 0 |
7–9. Period, summary and notice clock
| 7(i). Period | May 2026 |
|---|---|
| 7(iii). Seized goods | Not applicable:no seizure |
| 8. Annexure A issue/reply | Category5/25 credit/refund; rule 89(4), capital component 12000000. Reply:freight 6000000 is supported by prior 2B/laterreceipt; taxpayer argues capital 12000000 should also be allowed because used for exports, but the guide identifies this as contrary to NetITC exclusion. Other categories 1–4,6–24,26–38 not selected; HSN/notification not applicable. |
| 9. Notice receipt | 12 October 2026; cross-objection filed 20 October,8 days later;45-day deadline 26 November 2026 |
10. Demand/refund table, INR
| Head /component | Original | First appeal | Department asks | Taxpayer asks |
|---|---|---|---|---|
| CGST /refund | 51000000 | 54000000 | 51000000 | 60000000 |
| SGST /refund | 51000000 | 54000000 | 51000000 | 60000000 |
| IGST/cess refund | 0 | 0 | 0 | 0 |
| Total refund | 102000000 | 108000000 | 102000000 | 120000000 |
| All heads tax/interest/penalty/fees/others | 0 | 0 | 0 | 0 |
10. All non-refund rows
For each CGST,SGST,IGST,cess andtotal head, tax/interest/penalty/fees/others are 0 at original,firstAA andcross-objector stages. The source repeats the Penalty heading; its repeated cells are also 0, not a second levy.
11–14. Relief, reply and grounds
| 11. Reliefs claimed | Defend the 6000000 freight allowance; additionally seek 12000000 rejected capital component, giving totalrefund 120000000. This is pleaded relief, not endorsed entitlement. |
|---|---|
| 12. Annexure B summary | Erroneous-refund row:original 102000000,AA108000000,departmentstand 102000000,crossobjector 120000000; defendfreight 6000000,claimcapital 12000000. All other registration/revocation/ITC-demand/tax/penalty/interest/classification/other rows 0/not applicable. |
| 13. Grounds | Freightinvoice communicated April/received May can satisfy 16 without repeated May2B. Capital-goods argument relies only on export use; rule 89(4) expressly excludes it from NetITC, so this part is legally weak and may be rejected. |
| 14. Para-wise reply | Departmentground1:deny May-only 2B requirement, refer existing April2B/Mayreceipt. Ground2:denyfreightrefund erroneous, nootherconditiondisputed. Additionalcrossground:requestcapitalcomponent but disclose NetITC exclusion. Actualportal would require the attached complete para-wise reply; this model provides its complete text here. |
Verification /execution
The stated facts and records are affirmed solely within this fictional teaching scenario; nothing is concealed. Place:Bengaluru. Date:20 October 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..
Additional primary authority: Circular 207/1/2024-GST,26 June 2024, paragraphs 2/3(vi) PDF pages 2–3:Central departmental GSTAT20-lakh threshold; erroneous-refund amount in dispute is counted..
Period and legal consequences
Current APL06 includes the complete new party details, demand table, Annexure A issues/replies and Annexure B stage comparisons, not just a short generic objection. Forty-five days runs from receipt of notice of the other appeal, not from the A Aorder or from its filing. Further45-day condonation requires sufficient cause. Filing cross-objections does not make an otherwise inadmissible capital-goods refund correct.
Primary source and exact locator
Official notified form source: Actual FORM GST APL-06 at PDF pages 71–76; 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..
CGST Act and government-hosted Act and Rules compilation - Section 112(5)/(6); rules 110(2)/111(2); current APL06. Source and example revision: 21 October 2026.
Questions answered by this example
Who prepares or issues this form?
The respondent receiving notice of another party’s tribunal appeal/application. A party cross-objects against part of the same impugned order, within 45 days of notice receipt.
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..