What is the National Appellate Authority for Advance Ruling (NAAR)?

NAAR is the national-level appellate body under Section 101A CGST Act 2017 that hears appeals against conflicting advance rulings from AAAR bodies in two or more states. From April 2026, the GSTAT Principal Bench at New Delhi serves as NAAR following the 56th GST Council recommendation of 03 September 2025.

When will NAAR become operational?

The 56th GST Council meeting on 03 September 2025 recommended that the GSTAT Principal Bench act as NAAR from April 2026. Finance Minister Nirmala Sitharaman confirmed this at the GSTAT launch on 24 September 2025. Specific operational gazette notifications are awaited.

Can I appeal any AAAR order to NAAR?

No. Under Section 101B CGST Act, an appeal to NAAR lies only where conflicting advance rulings have been given by the AAAR in two or more states or union territories. An adverse ruling from one state alone is not appealable to NAAR. The remedy in such cases is a High Court writ under Article 226.

What is the time limit for a NAAR appeal?

30 days from the date of the AAAR order under Section 101B CGST Act. Condonation of up to 30 additional days may be granted on sufficient cause. Beyond the 60-day outer limit, the right to appeal to NAAR is permanently lost. This is the shortest appellate limitation in the GST framework.

What is the difference between AAR, AAAR, and NAAR?

AAR under Section 96 is the state-level first authority that pronounces advance rulings. AAAR under Section 99 is the state-level appellate authority. NAAR under Section 101A is the national authority that resolves conflicts between AAAR rulings of different states. From April 2026, NAAR is housed at the GSTAT Principal Bench at New Delhi.

Is pre-deposit required for a NAAR appeal?

No pre-deposit in the Section 112(8) sense. The fee for filing a NAAR appeal is Rs 10,000 under CGST plus state fee. This is significantly lower than the 10% pre-deposit required for GSTAT appeals under Section 112. NAAR appeals under Section 101B operate under a distinct advance ruling appellate framework.

What happens after NAAR passes an order?

The NAAR order harmonises the conflicting rulings and creates a binding ruling applicable pan-India on the question at issue. It supersedes the conflicting AAAR orders in all concerned states. Further appeal against a NAAR order lies to the High Court on substantial questions of law only.

What form is used for a NAAR appeal?

Form GST ARA-03 is the prescribed form under the CGST Rules. Once NAAR is operational at the GSTAT Principal Bench from April 2026, filing may migrate to the GSTAT e-filing portal at efiling.gstat.gov.in. Patron Accounting monitors all gazette notifications to ensure timely filing.

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GSTAT Appeal: Importers: Resolve Conflicting GST Rulings at GSTAT

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Dispute Types: IGST on imports valuation disputes and Customs-GST interface on integrated tax computation

Pre-Deposit: 10% pre-deposit at GSTAT stage under Section 112(8) CGST Act - capped at Rs 20 crore

Deadline: 3-month appeal deadline from order date under Section 112(1) CGST Act 2017

Specialist: GSTAT matters handled by Advocate Surbhi Premi - Former Partner, LKS

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Overview Import IGST Disputes Who Should File Our Services 7-Step Process Documents Pre-Deposit & Fees Why Patron GSTAT vs HC Writ Legal Framework FAQs

GSTAT Appeal for Importers - Overview

TL;DR: 1. File GSTAT appeal within 3 months under Section 112(1) CGST Act. 2. Pay 10% pre-deposit on disputed IGST amount under Section 112(8) - capped at Rs 20 crore. 3. Contact Patron Accounting for IGST on imports and customs valuation dispute representation.

Parameter	Details
Industry Focus	IGST on imports valuation (Section 3(7) CTA), Customs-GST interface, anti-dumping duty stacking, Bill of Entry disputes
Pre-Deposit	10% of disputed IGST under S.112(8) - capped at Rs 20 crore CGST
Time Limit	3 months from order communication under S.112(1)
Stay of Recovery	Automatic under S.112(9) on filing with pre-deposit
Filing Portal	efiling.gstat.gov.in via Form GST APL-05
Backlog Deadline	30 June 2026 for pre-1 April 2026 orders

Importers facing IGST valuation disputes arising from customs reassessment, anti-dumping duty and IGST stacking, or Bill of Entry amendment issues now have a dedicated appellate remedy through GSTAT. GSTAT appeal for importer IGST disputes under Section 112 CGST Act 2017 requires specialist representation combining knowledge of customs valuation under Section 3(7) Customs Tariff Act with tribunal litigation strategy. Patron Accounting provides this through our GSTAT practice.

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. Her Goldman Sachs background and deep expertise in GST, Customs, and Foreign Trade Policy enables viable solutions for complex import IGST valuation disputes, customs-GST interface issues, and anti-dumping duty challenges at GSTAT.

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What Is a GSTAT Appeal for Import IGST Valuation Disputes?

Definition: An import IGST valuation dispute arises when the customs authorities reassess the value of imported goods under Section 3(7) of the Customs Tariff Act 1975, resulting in additional IGST liability that the importer challenges as incorrect - whether due to valuation methodology, anti-dumping duty inclusion, or Bill of Entry amendment.

When the first appellate authority under Section 107 CGST Act upholds an IGST demand arising from customs valuation reassessment, the importer may file a second appeal before GSTAT under Section 112 CGST Act 2017 within 3 months of the order.

GSTAT vs Commissioner (Appeals): GSTAT, unlike the Commissioner (Appeals), is a judicial body - its orders carry the force of a court decree, making it the first genuinely independent forum for resolving import IGST valuation disputes in the GST appellate hierarchy.

Key Terms:

IGST on Imports - Levied under Section 3(7) Customs Tariff Act on assessable value plus duties
Customs Valuation - Assessable value under Customs Valuation Rules 2007
Anti-Dumping Duty - Additional duty under Section 9A CTA included in IGST base
Bill of Entry - Import declaration under Section 46 Customs Act 1962
Pre-Deposit - 10% of disputed IGST under Section 112(8), capped at Rs 20 crore

Import IGST Dispute Types Leading to GSTAT Appeal

Who Should File a GSTAT Appeal for Import IGST Disputes

Importers of goods, manufacturing importers, trading houses, and multinational companies with import operations that have received an adverse order from the Commissioner (Appeals) under Section 107 CGST Act should consider filing a GSTAT appeal. Common triggers include:

IGST on imports valuation demands - Customs reassessment of assessable value under Section 3(7) CTA
Anti-dumping duty and IGST stacking - IGST levied on anti-dumping duty creating cascading effect
Bill of Entry amendment disputes - Value or classification changes under Section 149 Customs Act
Transfer pricing adjustments on imports - Related party valuation under CVR 2007 Rule 12
Classification disputes affecting IGST rate - Incorrect HSN classification on imported goods

Under Section 112(1), the appeal must be filed within 3 months. For orders before 1 April 2026, importers may file until 30 June 2026.

6 GSTAT Services for Import IGST and Valuation Disputes

Service	What We Do
Import IGST Dispute Assessment	Analyse the IGST valuation demand, identify grounds of appeal based on customs valuation methodology, and calculate pre-deposit under Section 112(8)
Grounds of Appeal for Customs-GST Interface	Structure legal arguments on Section 3(7) CTA computation, anti-dumping duty inclusion, Bill of Entry value, and transfer pricing adjustments
Form GST APL-05 E-Filing	Complete electronic filing on efiling.gstat.gov.in with customs documentation and supporting evidence
Stay of Recovery Under Section 112(9)	Secure automatic stay against recovery of additional IGST demand during appeal proceedings
Hearing Representation	Advocate representation before all 31 State Benches and the Principal Bench at New Delhi
High Court Writ Under Article 226	Alternative remedy where GSTAT appeal window has expired or jurisdictional issues arise

Our Process

7 Steps to File a GSTAT Appeal for Import IGST Valuation Disputes

Our end-to-end process for importer GSTAT appeals under Section 112

Step 1

Review Impugned Order

Obtain the first appellate order relating to IGST valuation demand, customs reassessment, or anti-dumping duty stacking dispute.