If you need to challenge an order from the GST First Appellate Authority or Revisional Authority, Form GST APL-05 is the exact form you must file on the GSTAT e-filing portal. Unlike the first appeal (which uses Form APL-01 on the GST common portal at gst.gov.in), the GSTAT appeal uses a completely separate portal and form. Getting the form wrong, filling it incorrectly, or missing a field can delay your appeal by weeks or result in rejection. For a broader overview of the entire process, read our guide on how to file a GSTAT appeal.
This guide walks you through every tab and field of Form GST APL-05, explains the offline Excel utility, lists the documents you need to upload, and covers the common errors that cause the Registrar to return filings for correction.
What Is Form GST APL-05 and Why Does It Matter?
Form GST APL-05 is the prescribed electronic appeal form under Rule 110(1) of the CGST Rules, 2017, used by taxpayers to file a second appeal before the Goods and Services Tax Appellate Tribunal (GSTAT) under Section 112 of the CGST Act. It was introduced when the GSTAT became operational on 24 September 2025 and must be filed exclusively on the GSTAT e-filing portal at efiling.gstat.gov.in.
The form requires precise identification of the impugned order, complete party particulars, consecutively numbered grounds of appeal, and a demand calculation sheet. Upon filing, a provisional acknowledgment is issued in Form GST APL-02A Part A. After the Registrar’s scrutiny and removal of any defects, a final acknowledgment with an appeal number is issued in Form GST APL-02A Part B. The date of the provisional acknowledgment is treated as the date of filing, provided all documents are uploaded within 7 days. Businesses needing end-to-end filing support can explore GSTAT appeal filing services for structured guidance.
Key Terms You Should Know
Form GST APL-05: The prescribed electronic form for taxpayer appeals to the GSTAT under Rule 110(1) of the CGST Rules, 2017. Filed exclusively on efiling.gstat.gov.in.
Form GST APL-01: The form for the first appeal to the Commissioner (Appeals) under Section 107. Filed on the GST common portal at gst.gov.in. Do not confuse with APL-05.
Form GST APL-02A: The acknowledgment form. Part A is the provisional acknowledgment issued immediately. Part B is the final acknowledgment with appeal number issued after scrutiny.
Form GST APL-04: The summary of demand issued by the First Appellate Authority or Revisional Authority. This order is the one being challenged through Form APL-05.
Offline Excel utility: A downloadable Excel template from the GSTAT portal that allows pre-filling of appeal details offline. It generates a JSON file for upload, reducing errors during online filing.
Cause title: The formal header of the appeal that must state ‘In the Goods and Services Tax Appellate Tribunal’ followed by details of the impugned order, as required by Rule 19 of the GSTAT Procedure Rules 2025.
Scrutiny/Defect-cure: The Registrar’s review of the filed form. If defects are found, the appellant gets up to 30 days to correct them. If not corrected, the appeal may be rejected.
Who Needs to File Form GST APL-05?
Form GST APL-05 is used exclusively by taxpayers and their authorised representatives to file appeals before the GSTAT. The following entities must use this form:
- Any registered taxpayer aggrieved by an order of the First Appellate Authority under Section 107 of the CGST Act
- Any person aggrieved by an order of the Revisional Authority under Section 108
- Businesses whose ITC claims, refund applications, or registration matters were decided adversely at the first appeal stage
- Exporters whose refund rejections were upheld by the Commissioner (Appeals)
- Entities facing penalty-only orders confirmed at the first appellate level (post Finance Act 2025 amendment)
- Authorised representatives (CA, CS, advocate, or authorised GST practitioner) filing on behalf of the above entities
Important: The GST department does NOT use Form APL-05. When the Commissioner files an appeal before the GSTAT, the prescribed form is Form GST APL-07. Cross-objections by the respondent use Form GST APL-06.
Legal Framework: APL-01 vs APL-05 — First Appeal vs GSTAT Appeal
Understanding the difference between APL-01 and APL-05 is critical because filing the wrong form on the wrong portal is a non-curable error.
| Aspect | Form GST APL-01 (First Appeal) | Form GST APL-05 (GSTAT Appeal) |
|---|---|---|
| Purpose | Appeal to Commissioner (Appeals) | Appeal to GST Appellate Tribunal (GSTAT) |
| Governing Section | Section 107, CGST Act 2017 | Section 112, CGST Act 2017 |
| Governing Rule | Rule 108, CGST Rules 2017 | Rule 110, CGST Rules 2017 |
| Filing Portal | gst.gov.in (GST Common Portal) | efiling.gstat.gov.in (GSTAT Portal) |
| Appealable Order | Adjudication order (order-in-original) | First Appellate Authority or Revisional Authority order |
| Time Limit | 3 months + 1 month condonation | 3 months + 3 months condonation |
| Pre-deposit | 10% of disputed tax, max Rs 25 crore | Additional 10%, max Rs 20 crore per enactment |
| Filing Fee | As per GST portal | Rs 1,000/lakh, min Rs 5,000, max Rs 25,000 |
| Authentication | DSC/EVC on GST portal | DSC or Aadhaar e-Sign on GSTAT portal |
| Acknowledgment Form | GST APL-02 | GST APL-02A (Part A provisional, Part B final) |
| Offline Utility | GST APL-01 template (PDF annexure) | GSTAT offline Excel utility (JSON upload) |
This comparison shows that APL-05 operates on a completely separate portal with different rules, fees, and authentication requirements. The two forms must never be confused.
How to Fill Form GST APL-05: Tab-by-Tab Process
Step 1: Register/log in on the GSTAT e-filing portal.
Visit efiling.gstat.gov.in. If you already have a GSTIN, log in using your GSTIN credentials. Authorised Representatives not on the GST portal must register separately with email and mobile OTP verification, plus a proof of identity upload. Select your role (Taxpayer, Tax Officer, or Authorised Representative) and accept the disclaimer. For portal navigation help, explore GSTAT e-filing portal assistance.
Step 2: Validate your filing slot using ARN/CRN.
Enter the Acknowledgment Reference Number (ARN) or Case Reference Number (CRN) from your earlier Form GST APL-01 or APL-03 filed at the first appeal stage. The portal validates whether your filing window is currently active. For backlog cases (orders before 1 April 2026), all appeals can be filed until 30 June 2026.
Step 3: Download and pre-fill the offline Excel utility.
Download the offline Excel template from the GSTAT portal. Fill in all fields including grounds of appeal (each ground in a separately numbered paragraph), statement of facts, and relief sought. The utility generates a JSON file that can be uploaded directly into the portal, auto-populating multiple fields and eliminating manual typing errors.
Step 4: Tab 1 — Order Details.
Select the type of order being challenged (demand order, penalty order, registration cancellation, refund rejection, enforcement order, or other). Enter the order reference number and date. If the order in Form APL-04 is already available in the GSTN system, details are auto-populated. If not, you must enter them manually.
Step 5: Tab 2 — Case Details.
Enter case-specific information. The cause title must begin with ‘In the Goods and Services Tax Appellate Tribunal’ as required by Rule 19 of the GSTAT Procedure Rules 2025. Enter the designation of the authority whose order is being challenged, the case description, and the specific sections/rules under which the order was passed. You can copy-paste from the offline Excel sheet.
Step 6: Tab 3 — Appellant and Respondent Details (Parties).
Verify or enter full details of the appellant: name, parentage, GSTIN, address, and description. The respondent details (typically the jurisdictional GST officer) must also be completed. Each party must be on a separate line with consecutive numbering as mandated by Rule 19(3) of the GSTAT Procedure Rules.
Step 7: Tab 4 — Add Representative.
Add your authorised representative (if any). The representative must already be registered on the GSTAT portal for their name to appear in the dropdown. If not, they must register first. Upload the Vakalatnama (authorisation letter). This tab is mandatory if filing through a representative and optional for self-filing.
Step 8: Tab 5 — Demand Details.
Fill in the demand calculation sheet. Enter the total demand amount, the amount admitted by the appellant, and the disputed amount. The portal calculates the pre-deposit requirement: 100% of admitted liability + 10% of remaining disputed tax under Section 112(8). If the Form APL-04 data is not in the GSTN system, manually enter all figures. Verify that the pre-deposit has been paid via Bharat Kosh before proceeding.
Step 9: Tab 6 — Upload Documents.
Upload all required documents in PDF format (maximum 20 MB per file, scanned at 300 dpi or less). There is no restriction on the number of documents. Required uploads include: certified copy of the impugned order, detailed appeal memorandum with numbered grounds, affidavit, Vakalatnama, pre-deposit proof, and all supporting evidence. Non-English documents need certified translations.
Step 10: Pay filing fee and submit.
Navigate to the Court Fee payments tab. The fee is Rs 1,000 per Rs 1 lakh of disputed tax (min Rs 5,000, max Rs 25,000). Pay via the integrated Bharat Kosh gateway (online or offline with challan upload). Complete the checklist by selecting correct options. Digitally sign using DSC or Aadhaar e-Sign. Click Submit. The system generates a provisional acknowledgment (APL-02A Part A) and sends confirmation via SMS and email.
Documents to Upload with Form APL-05
- Form GST APL-05 completed via the portal (auto-saved during tab completion)
- Detailed appeal memorandum with consecutively numbered grounds of appeal, typed in double spacing on A4 format
- Certified copy of the impugned order (Form APL-04 from the First Appellate Authority or Revisional Authority)
- Copy of the original adjudication order (order-in-original)
- Copy of Form GST APL-01 or APL-03 filed at the first appeal stage with ARN/CRN
- Pre-deposit payment proof (Bharat Kosh challan or online payment receipt for Section 112(8) deposit)
- Filing fee payment proof (Bharat Kosh receipt)
- Vakalatnama or authorisation letter if filing through an authorised representative
- Statement of facts supporting the appeal
- All supporting evidence, annexures, and documentary proof (each PDF max 20 MB)
- English translation of any non-English document, certified by both parties or their representatives
- Index of all documents, properly paged and tagged as per Rule 30 of GSTAT Procedure Rules 2025
APL-05 Filing Fees and Pre-Deposit Requirements
Filing Form APL-05 involves two separate financial obligations: the filing fee (paid at the Court Fee tab) and the pre-deposit (paid before filing via Bharat Kosh on the GSTN portal).
| Component | Calculation | Cap/Minimum |
|---|---|---|
| Filing fee (tax/ITC disputes) | Rs 1,000 per Rs 1 lakh of disputed amount | Min Rs 5,000; Max Rs 25,000 |
| Filing fee (non-tax appeals) | Flat fee | Rs 5,000 |
| Filing fee (restoration of appeal) | Same as filing fee | Min Rs 5,000; Max Rs 25,000 |
| Interlocutory application fee | Flat fee | Rs 5,000 |
| Pre-deposit (tax disputes) | 100% admitted + 10% disputed tax (above first appeal deposit) | Rs 20 crore each CGST & SGST |
| Pre-deposit (penalty only) | 10% of disputed penalty | Capped under IGST only |
| Rectification application fee | No fee | Rs 0 (Rule 110(6)) |
Note: Pay the filing fee only after all data and documents are uploaded on the portal. The GSTAT User Advisory specifically recommends completing all tabs before proceeding to Court Fee payments. For complex pre-deposit computations involving multiple enactments, use pre-deposit calculation advisory services.
Common Mistakes to Avoid When Filling Form APL-05
Mistake 1: Filing on the wrong portal.
Form APL-05 must be filed on efiling.gstat.gov.in, NOT on gst.gov.in. The GST common portal is for Form APL-01 (first appeal) only. Filing on the wrong portal means your appeal is not registered with GSTAT and the limitation period continues to run.
Mistake 2: Not numbering grounds of appeal in separate paragraphs.
Rule 19 of the GSTAT Procedure Rules 2025 mandates that each ground of appeal must be stated in a separately numbered paragraph. Mixing multiple grounds in a single paragraph or not numbering them results in a defect notice from the Registrar.
Mistake 3: Uploading documents exceeding 20 MB per file.
The GSTAT portal restricts individual file uploads to 20 MB scanned at 300 dpi or less. If your document is larger, split it into multiple volumes and upload sequentially. Oversized files cause upload failures and may appear as missing documents during scrutiny.
Mistake 4: Not paying pre-deposit before filing.
The pre-deposit under Section 112(8) must be paid via Bharat Kosh before starting the APL-05 filing. If the Demand Details tab shows an unpaid pre-deposit, the form cannot be submitted. The GSTAT portal verifies payment status before allowing progression.
Mistake 5: Forgetting to register the authorised representative on the GSTAT portal.
If your CA, CS, or advocate is not registered on efiling.gstat.gov.in, their name will not appear in the Add Representative dropdown in Tab 4. They must register separately before you begin filling APL-05. Last-minute registration delays can push you past the filing deadline.
Consequences of Defective Filing of Form APL-05
A defective filing of Form APL-05 triggers the Registrar’s scrutiny process under Rules 22-24 of the GSTAT Procedure Rules 2025.
Under Rule 22 of the GSTAT Procedure Rules, the Registrar examines every filed appeal for completeness and compliance. If defects are identified — such as missing documents, incorrect cause title, unsigned affidavit, or incomplete demand details — the filing is returned with a defect notice specifying the corrections required.
The appellant gets up to 30 days to cure the defects and re-file. If the defects are not cured within this period, the Registrar may reject the appeal entirely. The Bench can restore a rejected appeal only if the appellant demonstrates sufficient cause for the failure to comply. The January 2026 office order from the GSTAT President provides some relief: for the first six months of operations, only substantive defects are being flagged, and minor procedural issues are being overlooked.
Additionally, documents generated digitally through the GSTN system (such as Form DRC-07, DRC-01, or ASMT-10 summaries) are exempted from certification requirements under the same office order. However, scanned copies of physical documents must still be signed by the authorised person.
How Form APL-05 Connects with Other GST Forms
Form APL-05 is one component in a chain of interconnected GST forms that track the lifecycle of a dispute. It begins with the adjudication order, which generates Form DRC-07 (demand summary). The first appeal is filed using Form APL-01, and the First Appellate Authority’s decision is communicated through Form APL-04. It is this APL-04 order that Form APL-05 challenges. After APL-05 is filed, the Registrar issues APL-02A Part A (provisional acknowledgment). Upon scrutiny, APL-02A Part B (final acknowledgment with appeal number) is issued. The respondent can file cross-objections using Form APL-06, and the GSTAT’s final order is communicated via Form APL-04A. For cross-objection matters, explore cross-objection filing in Form APL-06.
If the GSTAT order is unfavourable, the next step is an appeal to the High Court using Form GST APL-08 under Section 117 (only on substantial questions of law). For a detailed analysis of when to escalate, read our GSTAT vs High Court appeal guide. The withdrawal of an appeal filed via APL-05 is done through Form GST APL-05/07W, and the Tribunal decides within 15 days.
Understanding this form chain is essential because errors in earlier forms (like APL-01) can cascade into APL-05 issues. If your APL-01 ARN/CRN is not in the GSTN system, a special filing window applies from 31 December 2025 to 30 June 2026, and you must manually enter order details in APL-05 instead of relying on auto-population.
Form APL-01 vs Form APL-05: Complete Comparison
| Feature | Form APL-01 | Form APL-05 |
|---|---|---|
| Forum | Commissioner (Appeals) | GSTAT |
| Portal | gst.gov.in | efiling.gstat.gov.in |
| Tabs/Sections | Statement of facts, grounds, disputed amount, annexure upload | 6 tabs: Order, Case, Parties, Representative, Demand, Documents |
| Offline Utility | PDF annexure template | Excel utility with JSON upload |
| Max Upload Size | 5 MB per file | 20 MB per file |
| Authentication | DSC or EVC | DSC or Aadhaar e-Sign |
| Fee Structure | Per GST portal rules | Rs 1,000/lakh, min Rs 5,000, max Rs 25,000 |
| Acknowledgment | Form APL-02 | Form APL-02A (Part A + Part B) |
| Cause Title | Not specifically mandated | Mandatory: ‘In the GST Appellate Tribunal’ |
| Paragraph Format | Written submission (flexible) | Consecutively numbered paragraphs (mandatory) |
| Defect Cure Period | No specific rule | 30 days under GSTAT Procedure Rules |
Key Takeaways
Form GST APL-05 is the exclusive prescribed form for taxpayer appeals to the GSTAT under Rule 110(1) of the CGST Rules, 2017, filed electronically on efiling.gstat.gov.in — not on the GST common portal at gst.gov.in.
The form has six tabs (Order Details, Case Details, Parties, Add Representative, Demand, Upload Documents) that must be completed in sequence, with the offline Excel utility available to pre-fill data and reduce errors via JSON upload.
The filing fee is Rs 1,000 per Rs 1 lakh of disputed tax with a cap of Rs 25,000, and the pre-deposit of 10% of disputed tax under Section 112(8) must be paid via Bharat Kosh before the form can be submitted.
Defective filings are returned by the Registrar with 30 days to cure, and the January 2026 GSTAT office order provides temporary relief by limiting scrutiny to substantive defects only for the first six months of operations.
Form APL-05 must not be confused with Form APL-01 (first appeal to Commissioner Appeals) — the two forms use different portals, different rules, different fee structures, and different authentication methods.
Need Help Filing Form APL-05?
Correctly filling Form GST APL-05 requires precise drafting of consecutively numbered grounds of appeal, accurate demand computation under Section 112(8), and error-free navigation of the six-tab e-filing process on efiling.gstat.gov.in. With the Registrar actively scrutinising filings and the 30 June 2026 deadline for backlog cases approaching, professional preparation is essential.
Explore our GSTAT appeal filing services (know more) for end-to-end support — from form preparation and offline Excel utility drafting to portal filing and hearing representation.
For queries, reach out at +91 945 945 6700 or WhatsApp us directly.
