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GSTAT Appeal Filing in Hyderabad: Resolve Conflicting GST Rulings at GSTAT

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Full State Coverage: All 33 Telangana districts including Hyderabad, Rangareddy, Medchal-Malkajgiri, Warangal, and Karimnagar

IT & Pharma Expertise: ITC reversal, classification disputes, and export refund appeals for Hyderabad's IT/ITeS and pharma sectors

Of-Counsel Specialists: 15+ years indirect tax litigation experience for Hyderabad bench hearings at GST Bhavan

10% Pre-deposit Advisory: Strategic computation of reduced 10% pre-deposit under S.112(8) with Rs 20 crore cap per CGST/SGST

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“
We had conflicting classification rulings across three states on our cloud product. Patron Accounting's GSTAT team mapped every ruling, identified the exact points of conflict, and built a NAAR-ready case file. The depth was outstanding.
TD
Director
Manufacturing Company, Hyderabad
★★★★★
2 months ago
“
When we received a Section 74 demand order, Patron's CA team and their of-counsel specialists built a strong appeal case. They correctly identified the Telangana Commercial Taxes Department as respondent and drafted grounds addressing the TGST Act provisions.
GC
CFO
IT Services Company, Secunderabad
★★★★★
3 months ago
“
Patron's team handled our ITC reversal dispute from the CGST Secunderabad Commissionerate. The 10% pre-deposit computation and hardship waiver petition were prepared expertly. Their pharma sector classification knowledge was critical for our grounds.
CF
CFO
Pharma Company, Rangareddy
★★★★★
1 month ago
“
Patron correctly distinguished our Telangana GSTIN (code 36) filing from our Andhra Pradesh operations (code 37). The Hyderabad bench filing was coordinated seamlessly with sector-specific e-way bill penalty grounds.
SK
Suresh R.
Director, Logistics Company, Hyderabad
★★★★★
5 months ago
“
Our export refund dispute at the CGST Hyderabad Zone was handled with deep expertise. Patron's team addressed the IGST refund computation errors and filed comprehensive grounds at the Hyderabad bench. Virtual hearing coordination was excellent.
VP
VP Finance
Export IT Company, Hyderabad
★★★★★
4 months ago

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GSTAT Appeal Filing in Hyderabad - Overview

TL;DR

The Hyderabad GSTAT Bench covers all 33 Telangana districts - from the IT corridors of Hyderabad and Secunderabad to the industrial zones of Rangareddy and extending to Warangal, Karimnagar, and Nizamabad. The bench is operational since January 2026 at GST Bhavan. Pre-deposit is 10% under S.112(8) (reduced from 20%). File Form APL-05 on efiling.gstat.gov.in within 3 months. Patron Accounting's CA team handles proceedings end-to-end.

ParameterDetail
BenchHyderabad GSTAT Bench (Telangana State Bench)
JurisdictionAll 33 districts of Telangana including Hyderabad, Secunderabad, Rangareddy, Medchal-Malkajgiri
Bench StatusOperational (January 2026). Justice Sushil Kumar Sharma, Justice AP Ravi (JM), Dr DK Srinivas (TM). GST Bhavan, Hyderabad.
Pre-deposit10% of disputed tax under S.112(8) CGST Act. Max Rs 20 crore each CGST and SGST.
Limitation Period3 months from date of order under S.112(1). Transitional orders: 30 June 2026.
Circuit BenchNone
Filing ModeOnline only via efiling.gstat.gov.in
SGST AuthorityCommissioner of Commercial Taxes, Telangana (TGST), CT Complex, Nampally, Hyderabad
CGST AuthoritiesPrincipal Commissioner, CGST Hyderabad Zone + Commissioner, CGST Secunderabad Commissionerate

Telangana's IT/ITeS, pharmaceutical, and manufacturing sectors drive significant GST enforcement activity. The Commissioner of Commercial Taxes, Telangana and the CGST Hyderabad Zone issue demand orders that feed into this bench. The Telangana High Court has already directed taxpayers to use the GSTAT route now that the bench is functional. GSTIN state code 36 (Telangana) routes to Hyderabad; state code 37 (Andhra Pradesh) routes to Vijayawada.

Surbhi Premi - Advocate and Chartered Accountant, Of-Counsel to Patron Accounting
Of-Counsel - GSTAT Practice Lead

Surbhi Premi

Advocate & Chartered Accountant | Diploma in IFRS (ACCA, UK)

Former Partner, Lakshmikumaran & Sridharan15+ Years GST, Customs & FTPGoldman Sachs Alumni500+ Large Domestic & MNC Clients

Surbhi Premi led the Indirect Tax practice at Lakshmikumaran & Sridharan as Partner and served on LKS Team Velocity - a national GST task force handling high-sensitivity, high-impact industry matters. Her background at Goldman Sachs brings a unique blend of tax, risk, and international business understanding. A renowned ICAI faculty member and keynote speaker, her methodical approach combined with deep domain knowledge enables her to provide viable, holistic, and tax-efficient solutions for complex GST litigation and advance ruling disputes.

Financial ExpressHindu Business LineIndia Business Law JournalTaxsutraTIOLVIL

What Is GSTAT Appeal Filing in Hyderabad

Definition

GSTAT - the Goods and Services Tax Appellate Tribunal - is the statutory forum under Section 109 of the CGST Act for appeals against GST demand orders. The Hyderabad bench covers all Telangana districts. Businesses in Hyderabad, Rangareddy, and Medchal file appeals here under Section 112.

The Hyderabad bench was constituted under S.O. 3048(E) dated 31 July 2024, with jurisdiction defined in the November 2024 notification. The bench commenced operations in January 2026 with Justice Sushil Kumar Sharma, Justice AP Ravi (Judicial Members), and Dr DK Srinivas (Technical Member Centre). Proceedings are conducted at GST Bhavan, Hyderabad.

The pre-deposit was reduced from 20% to 10% per the Finance (No. 2) Act, 2024 following the GST Council's 53rd meeting recommendation. See GSTAT appeal filing services in India for the national hub.

Key terms: GSTAT appeal filing | S.112 CGST Act | TGST Act | Form APL-05 | 10% Pre-deposit under S.112(8) | Telangana HC | CGST Hyderabad Zone

IT/PHARMATelanganaGSTAT Appeal Filing - Hyderabad Bench

Who Needs GSTAT Appeal Filing in Hyderabad

Any taxpayer registered under the TGST Act or CGST Act whose place of business falls within Telangana can file a second appeal at the Hyderabad GSTAT bench. This includes businesses in all 33 districts - from the IT corridors of Hyderabad and Secunderabad to industrial zones of Rangareddy and Medchal-Malkajgiri, extending to Warangal, Karimnagar, Nizamabad, and Khammam.

Appeals arise from orders of the Commissioner of Commercial Taxes, Telangana (TGST), the Principal Commissioner, CGST Hyderabad Zone, or the Commissioner, CGST Secunderabad Commissionerate. GSTIN state code 36 (Telangana) goes to Hyderabad; state code 37 (AP) goes to Vijayawada. See also GSTAT appeal filing in Bengaluru and Chennai for neighbouring state benches.

Common Demand Categories in Telangana

  • ITC reversal demands under Section 16(2) read with Rule 36(4) - most common in pharma, IT, and manufacturing sectors
  • Classification disputes - IT/ITeS (software vs service), pharma (drug vs medical device)
  • Fake invoice and bogus ITC demands under Section 74 - growing category in CGST Hyderabad Zone
  • E-way bill violations under Sections 129/130 on major freight corridors
  • Export refund denials for Hyderabad's export-oriented IT and pharma companies
  • Adverse orders on GST notice responses requiring tribunal appeal

GSTAT Appeal Filing Services at Hyderabad Bench

ServiceWhat We Do
Appealability AssessmentReview demand from CGST Hyderabad Zone, CGST Secunderabad Commissionerate, or Commissioner of Commercial Taxes, Telangana (TGST). Confirm grounds under S.112.
Pre-deposit ComputationStrategic computation of 10% under S.112(8). Cap Rs 20 crore each. Hardship waiver guidance for large IT/pharma demands.
Form APL-05 DraftingDraft grounds specific to IT services ITC, pharma classification, fake invoice defence, and export refund disputes. GSTAT offline Excel utility.
E-Filing Portal NavigationEnd-to-end filing on efiling.gstat.gov.in. GSTIN code 36 routing to Hyderabad bench.
Bench Appearance (Hyderabad)Of-counsel GST litigation specialists attend admission, stay, and final arguments at GST Bhavan. Hybrid mode available.
CGST-TGST Dual FilingCoordinate separate appeals where a single transaction generates demands from both CGST Hyderabad Zone and Telangana Commercial Taxes.
Telangana-AP RoutingCorrectly distinguish GSTIN code 36 (Telangana/Hyderabad) from code 37 (AP/Vijayawada) for businesses with cross-state operations.
Post-Order AdvisoryAnalyse GSTAT order, advise on compliance or appeal to Telangana HC under S.113 within 180 days.
Our Process

GSTAT Appeal Filing Process at Hyderabad Bench - 6 Steps

Follow this step-by-step process. Patron Accounting's CA team manages every stage.

Step 1

Assess Appealability

Verify the demand order from the CGST Hyderabad Zone, CGST Secunderabad Commissionerate, or Commissioner of Commercial Taxes, Telangana (TGST) is appealable under S.112. Confirm the first appeal under Section 107 has been disposed of. Identify the specific authority that passed the original order within the Hyderabad bench jurisdiction.

Verify S.112 groundsIdentify CGST vs TGST authority
Order Review01
Step 2

Calculate Pre-deposit

Compute 10% of the remaining disputed tax under S.112(8). This is in addition to any deposit at the first appellate stage. Cap: Rs 20 crore each CGST and SGST (reduced from 20% per Finance (No. 2) Act, 2024). Patron's team advises on pre-deposit strategy and hardship waiver applications.

10% pre-depositCap Rs 20 crore each
Pre-deposit Paid02
Step 3

Prepare Form APL-05

Draft grounds of appeal in consecutively numbered paragraphs. Compile impugned appellate order, original demand order, certified copies, SCN and reply, GST returns (GSTR-1, GSTR-3B, GSTR-9). Include TGST-specific State Tax Officer references for Telangana SGST matters. Patron's CA team reviews all submissions.

IT/pharma specific groundsDocuments compiled
APL-05 Ready03
Step 4

File on GSTAT E-Filing Portal

Submit Form APL-05 at efiling.gstat.gov.in with pre-deposit proof (Bharatkosh challan) within 3 months under S.112(1). For transitional orders: file by 30 June 2026. GSTIN state code 36 (Telangana) routes automatically to the Hyderabad bench.

3-month limitationTransitional: 30 June 2026
E-Filed04
Step 5

Attend Admission Hearing

Patron's of-counsel GST litigation specialists with 15+ years of indirect tax experience appear at the Hyderabad bench. Hearings in hybrid mode - physical at GST Bhavan or virtual. Businesses in remote districts like Adilabad, Khammam, and Mahbubnagar can attend via video conferencing.

Hybrid hearing modeGST Bhavan, Hyderabad
Admission Hearing05
Step 6

Final Hearing and Order

Represent at final hearing, file written submissions, obtain GSTAT order. If unfavourable, appeal to the Telangana High Court under S.113 within 180 days on substantial questions of law. The Telangana HC has confirmed that writ jurisdiction should no longer be the default path.

Telangana HC under S.113180 days for HC appeal
Order Received06

Documents Required for GSTAT Appeal Filing at Hyderabad

  • Form APL-05 - GSTAT appeal form (mandatory, electronic via efiling.gstat.gov.in)
  • Certified copy of impugned order (S.107 appellate or S.108 revisional)
  • Original order-in-original (demand order from adjudicating authority)
  • Pre-deposit payment proof - Bharatkosh challan (10% under S.112(8))
  • GSTIN registration certificate (Telangana, state code 36)
  • Returns - GSTR-1, GSTR-3B, GSTR-9, GSTR-2A/2B for disputed period
  • Show Cause Notice and reply to SCN
  • Vakalatnama stamped per Telangana High Court rules
  • Affidavit supporting the appeal

Telangana-specific Requirement

For Telangana SGST matters, include the State Tax Officer's order reference and correspondence with the Commissioner of Commercial Taxes, CT Complex, Nampally. IT/ITeS businesses must provide SAC evidence. See also GST return filing for compliance documentation.

Challenges in GSTAT Appeal Filing at Hyderabad Bench

Multi-District GSTIN Complexity

Enterprises operating across Hyderabad, Rangareddy, and Secunderabad may hold multiple GSTINs. Identifying the correct appellate order and matching it to the Hyderabad bench requires careful analysis. See also GST audit support.

CGST-TGST Overlap

A single business may face demands from both CGST Hyderabad Zone and Telangana Commercial Taxes. Separate appeals may be required. The pre-deposit cap applies independently under CGST and SGST.

Pre-deposit for Large IT/Pharma Demands

Where the demand is substantial (ITC reversal in pharma or IT sectors), the 10% pre-deposit can represent significant cash outflow. Hardship waiver applications require separate interlocutory petitions.

Telangana-AP Confusion

Businesses with operations in both states may confuse Hyderabad bench (GSTIN code 36, Telangana) with Vijayawada bench (code 37, AP). Correct state code identification is critical.

Illustrative Scenario

An IT company in Hyderabad receives an Rs 85 lakh ITC reversal demand from the CGST Hyderabad Zone. The 10% pre-deposit amounts to Rs 8.5 lakh. Separately, a pharma company in Rangareddy faces a Section 74 demand from the Telangana Commercial Taxes Department. Both file at the Hyderabad bench, but with different respondent authorities. Patron's team handles the precise respondent identification and sector-specific grounds drafting.

Fees for GSTAT Appeal Filing at Hyderabad Bench

GSTAT appeal costs comprise statutory fees and professional charges.

ComponentAmount
Pre-deposit (Statutory)10% of disputed tax under S.112(8). Cap: Rs 20 crore each CGST/SGST. Non-payment = rejection at admission.
GSTAT Filing FeesRs 1,000 per Rs 1 lakh of tax/penalty, capped at Rs 25,000
Interlocutory Application FeesRs 5,000 per application (stay, condonation, early hearing)
Bharatkosh PaymentOnline via Bharatkosh through GSTAT portal
MiscellaneousCertified copy fees, notarization, Vakalatnama stamp per Telangana court fee schedule
Patron Accounting Professional FeesStarting from INR 24,999 (Exl GST and Govt. Charges)

All fees listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on volume and complexity of work.

Get a Case-Specific Estimate for Your Hyderabad Bench Proceedings

Our CA team assesses your demand order and advises on pre-deposit strategy.

Call +91 945 945 6700

Why Choose Patron Accounting for Hyderabad GSTAT Appeals

IT & Pharma Expertise

ITC reversal, software vs service classification, drug vs medical device disputes for Hyderabad's tech and pharma sectors.

Of-Counsel Specialists

15+ years indirect tax litigation. CESTAT and multiple High Court appearances by of-counsel practice lead.

CGST-TGST Dual Filing

Coordinate separate appeals from CGST Hyderabad Zone and Telangana Commercial Taxes for the same transaction.

Pan-India Coverage

All 32 GSTAT benches. Offices in Pune, Mumbai, Delhi, and Gurugram. See GSTAT appeal filing in Bengaluru.

10% Pre-deposit Expertise

Reduced pre-deposit computation per Finance (No. 2) Act, 2024. Hardship waiver applications for large demands.

Telangana-AP Routing

Correctly distinguish GSTIN code 36 (Telangana/Hyderabad) from code 37 (AP/Vijayawada) for cross-state businesses.

Trusted by 10,000+ Businesses for GST Litigation

Patron Accounting's CA team manages your case end-to-end. Our team understands the Telangana SGST administration and the CGST Hyderabad Zone's adjudication patterns, including IT/ITeS, pharma, and manufacturing sector disputes.

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron coordinates GSTAT representation nationally.

Patron Accounting vs Alternatives for Hyderabad GSTAT Appeals

FactorPatron + Of-CounselUnrepresentedGeneral CA Firm
GSTAT ExperienceDedicated practice across 32 benchesNone - first-time filingLimited or none
Hyderabad Bench KnowledgeTGST/CGST overlap understanding; IT/pharma expertiseNoneGeneric approach
Pre-deposit AdvisoryStrategic 10% computation, hardship waiverSelf-computed, error riskBasic calculation
Pan-India CoverageAll 32 benches from 4 officesSingle locationCity-limited
Of-counsel Specialists15+ years, HC/CESTAT experienceNot availableRarely available
E-filing CoordinationFull APL-05 preparation and portal filingSelf-managedVaries

Patron's dedicated GSTAT practice ensures precise CGST-TGST respondent identification, Telangana-AP routing, and sector-specific grounds. GST registration services also available.

Related GSTAT and GST Services

Patron Accounting provides comprehensive GST litigation and compliance services for Telangana businesses:

ProvisionSectionKey Requirement
GSTAT ConstitutionS.109, CGST ActHyderabad bench constituted under S.O. 3048(E) dated 31 July 2024; jurisdiction in November 2024 notification
Appeal to GSTATS.112, CGST/TGST Act3-month limitation; 10% pre-deposit under S.112(8); condonation under S.112(4); automatic stay under S.112(9)
Appeal to High CourtS.113, CGST ActTelangana HC on substantial questions of law within 180 days
Finance (No. 2) Act, 2024Amendment to S.112(8)Reduced pre-deposit from 20% to 10% per 53rd GST Council recommendation
CGST Amendment Act, 2023-Basis for bench constitution. 49th/52nd GST Council meetings recommended.
GSTAT Procedure Rules, 2025Notified 24 April 2025Governs filing, Form APL-05, documentation, hearings.
TGST Act, 2017-Telangana state legislation. Commissioner of Commercial Taxes, CT Complex, Nampally, Hyderabad.

Frequently Asked Questions

Quick Answers - GSTAT Appeal Filing in Hyderabad

Is the bench operational?

Yes. Commenced January 2026 with Justice Sushil Kumar Sharma, Justice AP Ravi, Dr DK Srinivas. Hybrid mode at GST Bhavan.

Where is the bench located?

GST Bhavan, Hyderabad (temporary). Permanent building under construction.

Can Secunderabad businesses file here?

Yes. All GSTIN state code 36 (Telangana) registrations file at the Hyderabad bench.

Does Patron have a Hyderabad office?

No. Cases coordinated from Pune, Mumbai, Delhi, and Gurugram offices. Of-counsel specialists appear at Hyderabad bench.

Monetary threshold?

GSTAT can refuse appeals below Rs 50,000. Above Rs 20 lakh eligible per GST Council limits.

Quick Answers

When does NAAR start?
GSTAT Principal Bench acts as NAAR from April 2026 per 56th GST Council recommendation.
What is the NAAR appeal deadline?
30 days from AAAR order under Section 101B. Condonation up to 30 additional days.
Who can file a NAAR appeal?
Any person affected by conflicting AAAR rulings in two or more states.
Is there a pre-deposit?
No - only Rs 10,000 filing fee under CGST.
Where is NAAR located?
GSTAT Principal Bench at New Delhi.
Can a single adverse ruling be appealed to NAAR?
No - conflicting rulings from 2+ states are required. Single adverse ruling remedy is HC writ.

Do Not Delay Your Hyderabad Bench GSTAT Appeal

Statutory Time Bar - Not Negotiable

Failure to file within the 3-month limitation period under S.112(1) CGST Act permanently extinguishes the right of appeal. Condonation under S.112(4) is discretionary and applied restrictively.

For transitional orders, 30 June 2026 is absolute. Every day of delay increases pre-deposit complexity as interest compounds. For Hyderabad businesses facing large IT/pharma demands, early filing locks in a lower pre-deposit quantum.

The bench is newly operational - early filers benefit from shorter cause lists and faster admission hearings.

Contact Patron's team today: +91 945 945 6700 | WhatsApp

File Your GSTAT Appeal at Hyderabad Bench - Start Today

The Hyderabad GSTAT bench provides Telangana businesses with a dedicated appellate forum for GST disputes - covering all 33 districts with no circuit arrangement. The bench hears appeals against orders from the Commissioner of Commercial Taxes, TGST, and the CGST Hyderabad Zone commissionerates.

Patron Accounting's representation model combines CA-led case management with of-counsel GST litigation specialists who bring 15+ years of indirect tax experience to the Hyderabad bench. From pre-deposit computation (10% under S.112(8)) through APL-05 filing and final hearing representation, the entire process is coordinated end-to-end. The 3-month limitation under S.112(1) is the statutory window - start your appeal preparation today.

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GSTAT State Bench Locations Across India

GSTAT has 32 State Benches across India. File your appeal at the bench covering your jurisdiction — Patron Accounting represents clients at all benches.

GSTAT State Bench Locations

Select your bench location to know jurisdiction districts and filing procedure

Vijayawada
Andhra Pradesh
Patna
Bihar
Raipur
Chhattisgarh
New Delhi
Delhi (NCT)
Mumbai
Goa + Maharashtra
Pune
Goa + Maharashtra
Nagpur
Maharashtra (Vidarbha)
Ahmedabad
Gujarat
Surat
Gujarat
Gurugram
Haryana
Shimla
Himachal Pradesh
Ranchi
Jharkhand
Bangalore
Karnataka
Dharwad
Karnataka (North)
Kochi
Kerala + Lakshadweep
Indore
Madhya Pradesh
Cuttack
Odisha
Chandigarh
Punjab + Chandigarh UT
Jalandhar
Punjab
Jaipur
Rajasthan
Jodhpur
Rajasthan (West)
Chennai
Tamil Nadu + Puducherry
Madurai
Tamil Nadu (South)
Hyderabad
Telangana (You are here)
Lucknow
Uttar Pradesh
Varanasi
Uttar Pradesh (East)
Prayagraj
Uttar Pradesh (Central)
Dehradun
Uttarakhand
Kolkata
WB + Sikkim + A&N
Siliguri
West Bengal (North)
Guwahati
Assam + NE States
Srinagar
J&K + Ladakh

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New Delhi
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Cross Objection Filing
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e-Filing Portal Assistance
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Content Created: 17 March 2026  |  Last Updated:  |  Next Review: 17 June 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed quarterly and updated whenever GSTAT Procedure Rules, bench operationality, jurisdiction notifications, or filing deadlines change. Last trigger: Hyderabad bench commenced operations January 2026.

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