FORM GST APL-07 - Commissioner-directed tribunal application with Annexures A–D
A Commissioner challenges specified points in a first appellate/revisional order.
Responsible actor: The subordinate officer specifically directed by the Commissioner. Provision: Section 112(3)/(4); rule 111; section 120.
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.
1–7. Department, respondent and order
| 1(a)/(b). Name/designation | N.Prakash /Assistant Commissioner; fictional unsigned |
|---|---|
| 1(c)/(d). Jurisdiction/Centre | Illustration CGST Bengaluru /Centre |
| 2. Respondent GSTIN | 29AABCA0000A1ZT |
| 3. Respondent name | Aster Learning Supplies Private Limited (fictional) |
| 4. Address | 12 Learning Park, Bengaluru, Karnataka 560001 (fictional) |
| 5. Order/date | ILLUSTRATION-APL04-D /30 September 2026 |
| 6. PassingAA/jurisdiction | S.Kumar, Joint Commissioner (Appeals), Illustration Bengaluru |
| 7. Communication | 30 September 2026; portal uploaded |
8–14. Dispute and grounds
| 8(a). Brief issue | Department challenges freight-service refund 6000000 because entry appeared in April rather than May2B; this is a disputed argument, not an asserted legal rule. |
|---|---|
| 8(b). Period | May 2026 |
| 8(c). Case summary | Annexure A /refund_compare below |
| 8(d). Seized goods | Not applicable:no seizure |
| 9. About respondent | Annexure B below |
| 10. Place of supply involved | No |
| 11. Facts | Annexure C history below |
| 12. Grounds | Commissioner’s limited direction alleges 6000000 freight credit failed May2B matching. Applicant seeks examination of its pleaded rule; the guide expressly notes prior 2B plus later receipt can satisfy 16 and the ground may fail. |
| 13. Prayer | Set aside only the 6000000 freight allowance; restore refund 102000000, without inventing a new adjudicated tax/penalty demand. |
| 14. Annexure D categories | 5 credit admissibility;25 refund allowance; section 16/89(4); amounts 6000000. Categories1–4,6–24,26–38:not selected; HSN/notification fields not applicable. |
15 /Annexure A. All amount positions, 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 |
Annexure A. Remaining case-summary issue rows
Registration, revocation, denial/blocking as separate demand, short/nonpayment, penalty, interest/latefee/fine, classification and other rows:all four-stage cells not applicable/0. Selected erroneous-refund row:original 102000000,firstAA108000000,departmentstand 102000000,presentclaim 102000000. No other amount is challenged.
Annexure B. Respondent constitution
| GSTIN | 29AABCA0000A1ZT |
|---|---|
| Constitution /other constitution | Private limited company /other not applicable |
| Address | 12 Learning Park, Bengaluru, Karnataka 560001 (fictional) |
| Nature /other facts | Stationery wholesaler making eligible zero-rated exports; no further material fact |
Case history
| Reference | Actor | Date | Facts |
|---|---|---|---|
| Refund-D | Aster | 10 June 2026 | May refund claim 120000000 |
| Order-D | Adjudicator | 15 July 2026 | Sanction102000000 |
| APL04-D | FirstAA | 30 September 2026 | Allows freight 6000000; total 108000000 |
| Direction-D | Commissioner | 5 October 2026 | Directs limited 6000000 challenge |
| APL07-D | Officer | 10 October 2026 | Tribunal application |
| Notice-D | Registry | 12 October 2026 | Notice to Aster |
| Cross-D | Aster | 20 October 2026 | Additional12000000 cross-objection |
Direction declaration and execution
N.Prakash declares solely within this fictional case that Commissioner direction ILLUSTRATION-DIRECTION-D dated 5 October 2026 authorises this 112(3) application; a true actual direction must accompany a real filing. Filed10 October 2026 at Bengaluru; designation:Assistant Commissioner; jurisdiction:Illustration CGST Bengaluru; signature:not executed. Filing is ten days after 30 September order, within six calendar months; no fabricated monetary-limit exception is invoked.
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
Use substituted 2025 APL07 and four annexures. Departmental112(3) runs six months from order-passing (not taxpayer communication clock), subject to any notified later date and lawful three-month sufficient-cause extension. Commissioner must identify the precise reviewed points. Taxpayer112(8) deposit gate is not mechanically imposed on the department. The 60-lakh challenge is above the Central20-lakh GSTAT monetary threshold; actual exceptions/directions must still be checked in real cases.
Primary source and exact locator
Official notified form source: Actual FORM GST APL-07 at PDF pages 76–82; 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(3)/(4); rule 111; section 120. 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 challenges specified points in a first appellate/revisional order.
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..