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

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Bench Coverage: 9 South Gujarat districts plus UT of Dadra and Nagar Haveli and Daman and Diu

Sector Expertise: Diamond, textile, petrochemical, and export-oriented dispute specialisation for Surat jurisdiction

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Gujarat 3-Forum Routing: Correct routing between Surat, Ahmedabad, and Rajkot circuit with GGST-UTGST distinction

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    GSTAT Appeal Filing in Surat - Overview

    TL;DR

    The Surat GSTAT Bench serves South and Central Gujarat - covering 9 Gujarat districts and the UT of Dadra and Nagar Haveli and Daman and Diu. Surat is India's diamond capital and a major textile hub generating substantial GST enforcement activity. File your appeal in Form APL-05 on efiling.gstat.gov.in within 3 months of the order date. Pre-deposit of 20% under S.112(8) is mandatory. For DNHDD businesses, UTGST applies instead of GGST. Patron Accounting's CA team handles proceedings end-to-end.

    ParameterDetails
    BenchSurat GSTAT Bench (Gujarat State Bench)
    JurisdictionSurat, Anand, Kheda, Tapi (Vyara), Narmada, Navsari, Bharuch, Valsad, Dang (9 Gujarat districts) + UT of Dadra and Nagar Haveli and Daman and Diu
    Circuit BenchNone (Rajkot circuit is under Ahmedabad bench)
    Bench StatusOperational. Technical Member (State): Rameshkumar Gokalbhai Hadvani. Members directed to join January 2026.
    Pre-deposit20% of disputed tax under S.112(8) CGST/GGST Act (cumulative). Cap: Rs 20 crore each CGST and SGST.
    Limitation Period3 months from date of order under S.112(1). Backlog appeals: deadline 30 June 2026.
    Filing ModeOnline only via efiling.gstat.gov.in - Form APL-05
    SGST AuthorityCommissioner of State Tax, Gujarat - Surat regional office
    CGST ZoneSurat CGST Zone (Surat-I and Surat-II Commissionerates)
    State LegislationGujarat Goods and Services Tax Act, 2017 (GGST Act)
    Other Gujarat BenchesAhmedabad (12 districts) + Rajkot circuit (12 Saurashtra districts)

    Gujarat is among India's top GST-contributing states. The Surat CGST Zone alone handles a significant share of Gujarat's indirect tax base, driven by the diamond and textile sectors. Businesses in Surat, Bharuch's petrochemical corridor, Valsad's pharmaceutical units, and the industrial estates of Dadra and Nagar Haveli that previously had to travel to Ahmedabad for appellate proceedings now have a dedicated forum. The Commissioner of State Tax, Gujarat administers GGST enforcement, while two CGST Commissionerates (Surat-I and Surat-II) handle central tax matters.

    Subham Jhunjhunwala - CA Finalist and Accounting and Tax Professional at Patron Accounting
    Accounting & Tax Professional

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    CA Finalist Accounting & Taxation GST & Compliance

    Subham Jhunjhunwala is a CA Finalist and Accounting & Tax Professional at Patron Accounting LLP, focused on accounting, taxation, and compliance. He works alongside the firm's CA and CS team on GST and GSTAT appeal matters.

    What Is GSTAT Appeal Filing in Surat

    Definition

    GSTAT - the GST Appellate Tribunal - is the statutory forum under CGST Act S.109 for appeals against GST demand orders. The Surat bench covers 9 South Gujarat districts plus the UT of DNHDD. Businesses in Surat, Bharuch, Valsad, and Silvassa file appeals here under S.112.

    The Surat GSTAT Bench was constituted under S.O.3048(E) dated 31 July 2024, with jurisdiction notified under S.O.5063(E) dated 26 November 2024. Technical Member (State) Rameshkumar Gokalbhai Hadvani was appointed at the Surat bench, with members directed to join by 21 January 2026.

    Gujarat has a unique 3-forum GSTAT structure: the Surat bench (9 districts + DNHDD UT), the Ahmedabad bench (12 North and Central Gujarat districts), and the Rajkot circuit (12 Saurashtra districts under Ahmedabad bench). Businesses must file at the correct forum. The Surat bench jurisdiction covers India's diamond capital and one of the country's most export-intensive industrial regions.

    Key terms: GSTAT appeal filing | S.112 CGST Act | GGST Act | UTGST Act | Form APL-05 | Pre-deposit under S.112(8) | Surat CGST Zone

    South Gujarat GSTAT Appeal Filing - Surat Bench

    Who Needs GSTAT Appeal Filing at the Surat Bench

    Any registered taxpayer or GST-registered business in South Gujarat or the UT of Dadra and Nagar Haveli and Daman and Diu that has received an unfavourable order from the First Appellate Authority under Section 107 or the Revisional Authority under Section 108 of the CGST/GGST Act can file a second appeal before the Surat GSTAT Bench under Section 112.

    Gujarat's 3-Forum Structure - Critical Routing

    Gujarat and the UT of DNHDD are served by two GSTAT benches plus a circuit. The Surat bench covers 9 South Gujarat districts and the UT. The Ahmedabad bench covers 12 North and Central Gujarat districts. The Rajkot circuit (under Ahmedabad bench) covers 12 Saurashtra districts. Filing at the wrong bench causes procedural rejection. Businesses in Vadodara must file at Ahmedabad, not Surat.

    The Surat bench jurisdiction covers the economic powerhouse of South Gujarat - from Surat city's diamond polishing and textile manufacturing zones through Bharuch's petrochemical corridor to Valsad's pharmaceutical cluster. The UT of DNHDD adds a cross-UT dimension, with Silvassa's industrial estates and Daman's manufacturing units.

    Common Demand Categories in Surat Jurisdiction

    • Diamond sector ITC disputes - classification of rough and polished diamonds, export refund claims
    • Textile classification disputes on man-made fibre (MMF) fabrics and yarn
    • Petrochemical ITC disputes from the Bharuch-Ankleshwar GIDC corridor
    • DNHDD industrial estate manufacturing-related demand orders
    • E-way bill violations along the Mumbai-Ahmedabad national highway corridor
    • Adverse orders on GST notice responses requiring tribunal appeal

    GSTAT Appeal Filing Services at Surat Bench

    ServiceWhat We Do
    Appealability AssessmentReview demand order from Surat CGST Zone (Surat-I/II), Vadodara CGST Zone (Bharuch/Anand/Kheda), or Gujarat State Tax. For DNHDD, verify CGST/UTGST authority.
    Pre-deposit ComputationStrategic computation of 20% under S.112(8). GGST for Gujarat districts, UTGST for DNHDD. Hardship waiver guidance for high-value diamond sector disputes.
    Form APL-05 DraftingDraft grounds specific to diamond valuation, textile HSN classification, and petrochemical ITC disputes. Use GSTAT offline Excel utility.
    E-Filing Portal NavigationEnd-to-end filing on efiling.gstat.gov.in with correct routing to Surat bench (not Ahmedabad/Rajkot).
    Bench Appearance (Surat)Of-counsel GST litigation specialists attend admission, stay applications, and final arguments at the Surat bench.
    Gujarat 3-Forum RoutingCorrectly route your appeal between Surat, Ahmedabad, and Rajkot circuit based on district of registration.
    DNHDD UTGST AdvisoryHandle the CGST-UTGST distinction for businesses registered in Silvassa, Daman, or Diu.
    Post-Order AdvisoryAnalyse GSTAT order, advise on compliance or appeal to Gujarat HC at Ahmedabad under S.113.
    Our Process

    GSTAT Appeal Filing Process at Surat Bench - 6 Steps

    Follow this step-by-step process to file your GSTAT appeal at the Surat bench. Patron Accounting's CA team manages every stage.

    Step 1

    Assess Appealability

    Verify that the demand order from Surat CGST Commissionerate (Surat-I or Surat-II), CGST Commissionerate Vadodara (for Bharuch, Anand, Kheda), or the Commissioner of State Tax, Gujarat is appealable under S.112. For DNHDD businesses, verify the CGST or UTGST authority. Patron's CA team reviews the order to confirm forum and grounds.

    Verify S.112 groundsGGST vs UTGST check
    Order Review01
    Step 2

    Calculate Pre-deposit

    Compute 20% of disputed tax under S.112(8). Cumulative: 10% from first appeal + 10% for GSTAT. Cap: Rs 20 crore each CGST and SGST (or UTGST for DNHDD). For penalty-only demands, 10%. Payment through Electronic Cash Ledger. Patron's team advises on pre-deposit strategy for Surat's high-value diamond and textile sector disputes.

    20% cumulativeUTGST for DNHDD
    PRE-DEPOSIT
    Pre-deposit Paid02
    Step 3

    Prepare Form APL-05

    Draft grounds of appeal with consecutively numbered paragraphs. Surat matters often involve complex diamond valuation, textile HSN classification, and export refund disputes. Compile supporting documents, obtain certified copies. The GSTAT portal offline Excel utility generates JSON for upload. Patron's CA team reviews all submissions.

    Sector-specific groundsExcel utility used
    APL-05
    APL-05 Ready03
    Step 4

    File on GSTAT E-Filing Portal

    Submit Form APL-05 at efiling.gstat.gov.in with pre-deposit proof within 3 months of order date under S.112(1). Ensure filing is routed to the Surat bench - not Ahmedabad or Rajkot circuit. DNHDD businesses must file at Surat. Backlog appeals: deadline 30 June 2026.

    3-month limitationCorrect bench routing
    SUBMIT
    E-Filed04
    Step 5

    Attend Admission Hearing

    Patron's of-counsel GST litigation specialists with 15+ years of indirect tax experience appear at the Surat bench for admission proceedings. Hearings are conducted in hybrid mode - both physical and video conferencing options are available.

    Hybrid hearing modeOf-counsel appearance
    Admission Hearing05
    Step 6

    Final Hearing and Order

    Represent at final hearing, file written submissions, obtain GSTAT order. Order pronouncement within 30 days. Appeal to the Gujarat High Court at Ahmedabad under S.113 lies only on a question of law arising from the GSTAT order.

    Order within 30 daysGujarat HC appeal option
    GSTAT ORDER
    Order Received06

    Documents Required for GSTAT Appeal Filing at Surat

    • Form APL-05 - GSTAT appeal form (filed electronically on efiling.gstat.gov.in)
    • Certified copy of impugned order from First Appellate Authority or Revisional Authority
    • Pre-deposit payment proof from Electronic Cash Ledger
    • GSTIN registration certificate
    • Returns (GSTR-1, GSTR-3B, GSTR-9) for the disputed period
    • Show Cause Notice (SCN) and reply to SCN
    • Assessment or adjudication order from original authority
    • Vakalatnama in GSTAT FORM-04 stamped per Gujarat High Court rules
    • Affidavit supporting the appeal
    • English or Hindi translations of any Gujarati-language documents

    Surat-specific Requirements

    Diamond sector appellants must include detailed diamond grading reports, export invoices, and Kimberley Process certificates where relevant. Textile businesses should attach HSN classification evidence and fabric test reports. DNHDD businesses must clearly identify whether the demand is under CGST or UTGST as the respondent authority differs. See also GST return filing for compliance documentation.

    Challenges in GSTAT Appeal Filing at Surat Bench

    Gujarat 3-Forum Routing

    The primary routing challenge is distinguishing Surat bench jurisdiction from Ahmedabad. Vadodara district, despite being in Central Gujarat and geographically closer to Surat, falls under the Ahmedabad bench. Businesses in Anand and Kheda file at Surat, not Ahmedabad. Rajkot/Saurashtra goes to the Rajkot circuit under Ahmedabad bench. See also GSTAT appeal filing in Ahmedabad.

    GGST vs UTGST Distinction

    DNHDD businesses are subject to UTGST, not GGST. The respondent and pre-deposit computation differ. Filing under wrong Act creates admission issues. Patron's CA team manages this distinction accurately.

    High-Value Diamond Disputes

    Surat's diamond sector generates multi-crore disputes. Pre-deposit of 20% on diamond ITC demands can be a significant financial burden even for large polishing units. Non-payment under S.112(8) results in rejection at admission. See also GST audit support.

    Dual CGST Zone Coverage

    The Surat CGST Zone (Surat-I and Surat-II) covers the city, while the Vadodara CGST Zone handles Bharuch and parts of Central Gujarat. Correctly identifying the respondent commissionerate is essential.

    Illustrative Scenario

    A diamond polishing unit in Surat receives an Rs 1.2 crore ITC reversal demand from Surat-I CGST. The 20% pre-deposit amounts to Rs 24 lakh. A manufacturing unit in Silvassa (DNHDD) receives a Rs 30 lakh penalty demand - this falls under UTGST, not GGST, and the respondent is the UTGST administrator, not Gujarat State Tax. Patron's team handles both cases with correct routing and computation.

    Fees for GSTAT Appeal Filing at Surat Bench

    GSTAT appeal costs at the Surat bench comprise statutory government fees and professional service charges.

    ComponentAmount
    Pre-deposit (Statutory)20% of disputed tax under S.112(8) CGST/GGST/UTGST Act (cumulative). Cap: Rs 20 crore each. For penalty-only demands: 10%.
    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 or offline via BharatKosh portal
    Gujarati Translation FeesFor Gujarat State Tax orders in Gujarati (if applicable)
    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 Surat Bench Proceedings

    Our CA team assesses your demand order and advises on pre-deposit strategy for diamond, textile, and DNHDD disputes.

    Call +91 945 945 6700

    Why Choose Patron Accounting for Surat GSTAT Appeals

    Gujarat 3-Forum Expertise

    Correctly routes your appeal between Surat, Ahmedabad, and Rajkot circuit. Manages the GGST-UTGST distinction for DNHDD cases.

    Of-Counsel Specialists

    15+ years indirect tax litigation experience. Supporting GSTAT appeal preparation and filing.

    Diamond and Textile Expertise

    Specialised grounds for diamond valuation, textile HSN classification, and export refund disputes unique to South Gujarat.

    Pan-India Coverage

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

    DNHDD UT Handling

    Expert handling of the UTGST-GGST distinction for businesses in Silvassa, Daman, and Diu with correct respondent identification.

    End-to-End Filing

    Pre-deposit computation through Form APL-05 drafting to GSTAT e-filing portal submission and Surat bench appearance.

    Trusted by 10,000+ Businesses for GST Litigation

    Patron Accounting's CA team manages your case end-to-end. Our team understands the specific enforcement patterns of the Surat CGST Zone and Gujarat State Tax authorities, including the complex diamond valuation, textile classification, and petrochemical ITC disputes unique to South Gujarat.

    With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting coordinates GSTAT representation nationally. See also GSTAT appeal filing in Pune for neighbouring state bench coverage.

    Patron Accounting vs Alternatives for Surat GSTAT Appeals

    FactorPatron AccountingUnrepresented AppellantGeneral CA Firm
    GSTAT Filing ExpertiseDedicated practice across 32 benchesNo tribunal experienceLimited GSTAT exposure
    Surat Bench KnowledgeGujarat 3-forum routing; DNHDD UT handling; diamond/textile expertiseMay file at wrong benchMay not know UTGST nuance
    Pre-deposit AdvisoryStrategic, sector-specific computationRisk of rejectionBasic computation
    Of-counsel Specialists15+ years indirect tax litigationSelf-representationMay outsource
    Pan-India CoverageAll 32 benchesSingle locationLimited
    E-filing SupportEnd-to-end correct routingRouting errorsMay need training

    Unlike unrepresented appellants who risk procedural rejections from incorrect bench selection or GGST-UTGST confusion, Patron Accounting's dedicated GSTAT practice ensures compliance at every stage. GST registration services are also available.

    Which districts fall under the Surat GSTAT bench jurisdiction?

    The Surat bench covers 9 Gujarat districts (Surat, Anand, Kheda, Tapi, Narmada, Navsari, Bharuch, Valsad, Dang) and the UT of Dadra and Nagar Haveli and Daman and Diu. Other Gujarat districts go to the Ahmedabad bench (12 districts) or Rajkot circuit (12 Saurashtra districts).

    Is the Surat GSTAT bench operational?

    Yes. Members were allotted via GSTAT Order No. 03/2025 dated 26 December 2025. Technical Member (State) Rameshkumar Gokalbhai Hadvani was appointed at the Surat bench. Members were directed to join by 21 January 2026. Hearings operate in hybrid mode.

    What is the pre-deposit for filing at Surat GSTAT bench?

    Pre-deposit under S.112(8) CGST/GGST Act is 20% of disputed tax (cumulative). For DNHDD businesses, UTGST applies instead of GGST. Cap: Rs 20 crore each. For penalty-only demands, 10%. Payment through Electronic Cash Ledger. Non-payment results in rejection at admission.

    What is the deadline for filing at Surat GSTAT bench?

    3 months from date of order under S.112(1). Condonation under S.112(4) is discretionary and the Gujarat HC applies this restrictively. Backlog appeals for orders before 1 April 2026 must be filed by 30 June 2026.

    Does the Surat bench cover Dadra and Nagar Haveli and Daman and Diu?

    Yes. The UT of Dadra and Nagar Haveli and Daman and Diu falls under the Surat bench. Businesses in Silvassa, Daman, or Diu file GSTAT appeals at Surat. Note that DNHDD businesses are subject to UTGST, not GGST, which affects respondent identification and pre-deposit computation.

    What is the difference between Ahmedabad, Surat, and Rajkot GSTAT forums?

    Gujarat has two benches and one circuit. Ahmedabad covers 12 North and Central Gujarat districts including Vadodara. Surat covers 9 South Gujarat districts plus DNHDD UT. Rajkot circuit operates under Ahmedabad bench for 12 Saurashtra districts. Filing at the wrong forum results in procedural rejection.

    Can I appeal a Surat GSTAT order to the Gujarat High Court?

    An appeal under S.113 lies to the Gujarat High Court at Ahmedabad on a question of law arising from the GSTAT order. The GSTAT is the highest fact-finding authority. Only legal errors can be challenged before the HC.

    What CGST commissionerates operate in the Surat bench jurisdiction?

    The Surat CGST Zone covers Surat city through Surat-I and Surat-II Commissionerates. The Vadodara CGST Zone covers Bharuch, Anand, Kheda, and Narmada. The correct commissionerate must be named as respondent based on which authority passed the original order.

    Quick Answers - GSTAT Appeal Filing in Surat

    Can I file offline?

    No. Rule 18 mandates online filing via efiling.gstat.gov.in.

    Does Rajkot circuit cover Surat bench districts?

    No. Rajkot circuit operates under Ahmedabad bench for Saurashtra only. Surat bench has no circuit.

    Are Gujarati-language orders accepted?

    GSTAT accepts English and Hindi. Gujarati orders require certified translation.

    Does Vadodara fall under Surat bench?

    No. Vadodara is under the Ahmedabad bench despite its proximity to Surat.

    Is DNHDD treated as Gujarat for GSTAT?

    DNHDD falls under Surat bench but applies UTGST (not GGST). The respondent is CGST or UTGST administrator.

    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.

    Why You Must Act Now for Your Surat GSTAT Appeal

    Statutory Time Bar - Not Negotiable

    The 3-month limitation under S.112(1) CGST/GGST Act permanently extinguishes the right of appeal. The Gujarat HC has applied condonation restrictively.

    For South Gujarat businesses with orders before 1 April 2026, the backlog deadline is 30 June 2026. Surat's massive diamond and textile sectors will generate heavy filing volumes - early filers benefit from shorter queues.

    Every day of delay increases pre-deposit complexity as interest compounds. The demand becomes enforceable once limitation expires. Surat's high-value diamond disputes make timely filing especially critical.

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

    File Your GSTAT Appeal at Surat Bench - Start Today

    The Surat GSTAT Bench provides South Gujarat businesses and DNHDD enterprises across 10 jurisdictions with a dedicated appellate forum. The bench serves India's diamond capital and one of the country's most export-intensive industrial regions. GSTAT appeal filing in Surat requires precision - from routing within Gujarat's 3-forum structure to computing pre-deposit under S.112(8), distinguishing GGST from UTGST for DNHDD, and drafting grounds in Form APL-05.

    Patron Accounting's CA team manages every stage, with of-counsel GST litigation specialists appearing at the Surat bench. The 3-month limitation period under S.112(1) is the statutory window. Start your appeal preparation today.

    Book a Free Consultation - No Obligation.

    Content Created: 17 March 2026  |  Last Updated: 17 March 2026  |  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: Surat bench members directed to join January 2026.