Rule 109B of the CGST Rules, 2017

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GST›CGST Rules, 2017›Chapter XIII, Appeals and Revision

At a glance

Bars, duties and time limits

109B(1)The Revisional Authority must serve FORM GST RVN-01 and give a reasonable opportunity of being heard before the proposed adverse revisional order under section 108.
109B(2)The authority must issue FORM GST APL-04 with its order, clearly indicating the final demand confirmed.

Procedure, powers and definitions

109B(1)The law does not settle what makes the hearing opportunity reasonable in a particular case; the rule specifies no minimum notice period.

Rule 109B requires notice and a reasonable hearing opportunity before a revisional order likely to affect a person adversely. The Revisional Authority uses the prescribed notice form for that purpose. When issuing its order under section 108(1), it must also issue a separate summary that clearly states the final amount of demand confirmed by the order.^[1]

Quick facts

Rule 109B, CGST Rules, 2017

Notice to person and order of revisional authority in case of revision

Provision
Act	Central Goods and Services Tax Rules, 2017
Chapter	XIII, Appeals and Revision
Rule title	Notice to person and order of revisional authority in case of revision
Amendments
Last amendment	31 December 2018: Inserted vide Notification No. 74/2018-CT dated 31.12.2018.
Amendments	1 footnote in the CBIC text (table)
Related provisions
Sections	Section 108 of the CGST Act, 2017
Forms named	FORM GST APL-04, FORM GST RVN-01
Structure 109B(1)Adverse revision notice and hearing 109B(2)Revision order summary
Source
Law text	CBIC tax information portal, served on 17 September 2026^[1]

Text

The text below is the rule as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.^[1] The Rules as published in the Gazette of India is the legal source.

Rule 109B, verbatim (show)

1 [Rule 109B. Notice to person and order of revisional authority in case of revision. -

(1) Where the Revisional Authority decides to pass an order in revision under section 108 which is likely to affect the person adversely, the Revisional Authority shall serve on him a notice in FORM GST RVN-01 and shall give him a reasonable opportunity of being heard.

(2) The Revisional Authority shall, along with its order under sub-section (1) of section 108, issue a summary of the order in FORM GST APL-04 clearly indicating the final amount of demand confirmed.]

1. Inserted vide Notification No. 74/2018-CT dated 31.12.2018.

Questions to answer on the file

Questions a reviewer answers from the engagement file, grouped by the part of the rule they come from. They describe what the rule asks; they do not decide it.

Adverse revision notice and hearing 109B(1)

Questions to answer on the file6 questions

Did the Revisional Authority decide to pass this order in revision under section 108?
Is this proposed revisional order likely to affect this person adversely?
Is this notice in FORM GST RVN-01?
Was this same notice actually served on this person?
Was this person given an opportunity of being heard?
Was that hearing opportunity reasonable for this person?

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Revision order summary 109B(2)

Questions to answer on the file4 questions

Did the Revisional Authority issue its section 108(1) order?
Was a summary issued along with that same order?
Is that summary in FORM GST APL-04?
Does it clearly indicate the final amount of demand confirmed?

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Amendment history

The CBIC text carries 1 footnote. The table gives each in the source's own terms. Effective dates are as the footnotes state them.^[1]

Amendments to Rule 109B as footnoted in the CBIC text
Note	Change
1	Inserted vide Notification No. 74/2018-CT dated 31.12.2018.^[2]

Provisions connected to Rule 109B
Provision	Connection	Words that tie them
Section 108 of the CGST Act, 2017	this provision requires Section 108 of the CGST Act, 2017	109B(1) "revision under section 108"

Circulars and notifications

Circulars and notifications in the CBIC repository that cite this rule, newest first, by number, date and subject. A listing here does not say what an instrument decides; read the instrument.

Notifications (2)

Number	Date	Subject
Notification No. 26/2022-Central Tax	26 December 2022	Seeks to make fifth amendment (2022) to CGST Rules
Notification No. 74/2018-Central Tax	31 December 2018	Fourteenth amendment to the CGST Rules, 2017. amended by a later instrument

Unsettled questions

The words of Rule 109B do not answer this question. Where one decides a matter on the file, the answer depends on the position taken on it.

What makes the opportunity of being heard reasonable before an adverse revisional order under Rule 109B(1), where no minimum notice period is specified?

References

Central Board of Indirect Taxes and Customs. "Rule 109B. Notice to person and order of revisional authority in case of revision". Central Goods and Services Tax Rules, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.
Notification No. 74/2018-Central Tax, dated 31 December 2018: Fourteenth amendment to the CGST Rules, 2017. Cited in CBIC footnote 1.

External links

CGST Rules, 2017, Rule 109B on the CBIC tax information portal