Rule 110 of the CGST Rules, 2017

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

At a glance

Entitlement and conditions

  • 110(4)Final acknowledgement in Part B of FORM GST APL-02A follows removal of defects. If the order is on the portal, or a self-certified copy of an absent order is submitted or uploaded within seven days, the provisional acknowledgement date is the filing date.

Bars, duties and time limits

  • 110(4) proviso and ExplanationA copy submitted or uploaded after seven days makes that later date the filing date. The appeal is treated as filed only after final acknowledgement carrying the appeal number.
  • 110(5)The appeal or restoration fee is one thousand rupees for every one lakh rupees of the specified tax, credit, difference, fine, fee or penalty amount, with a minimum of five thousand rupees and a maximum of twenty five thousand rupees.

Procedure, powers and definitions

  • 110(1)–(3)The appeal uses FORM GST APL-05 with relevant documents and cross-objections use FORM GST APL-06. Rule 26 governs signatures. Provisional acknowledgement is issued immediately in Part A of FORM GST APL-02A. The manual-filing provisos were omitted from 22 September 2025.
  • 110(5) proviso and (6)An appeal against an order without any demand of tax, interest, fine, fee or penalty carries a five thousand rupee fee. An application for rectification under section 112(10) carries no fee.
  • 110The law does not settle the precise interval for immediate acknowledgement, treatment of a fractional lakh, or the fee base where several specified amount categories coexist.

Rule 110 governs appeals and cross-objections before the Appellate Tribunal under section 112. It prescribes electronic forms, authentication, acknowledgement and filing-date rules. A self-certified order copy is required where the challenged order is absent from the portal. The rule also sets appeal and restoration fees, subject to minimum and maximum amounts, and exempts applications to rectify specified errors from a fee.[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 110, verbatim (show)

Rule 110

1[Rule 110. Appeal to the Appellate Tribunal.-

(1) An appeal to the Appellate Tribunal under sub-section (1) of section 112 shall be filed in FORM GST APL-05, along with the relevant documents, electronically and provisional acknowledgement 7[in Part A of FORM GST APL-02A] shall be issued tothe appellant immediately:

8[****]

(2) A memorandum of cross-objections to the Appellate Tribunal under sub-section (5) of section 112, if any, shall be filed electronically in FORM GST APL-06:

Provided that the memorandum of cross-objections may be filed manually in FORM GST APL-06, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order.

(3) The appeal and the memorandum of cross objections shall be signed in the manner specified in rule 26.

(4) Where the order appealed against is uploaded on the common portal, a final acknowledgement, indicating appeal number, shall be issued 10[in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of issue of the provisional acknowledgement shall be considered as the date of filing of appeal under sub-rule (1):

Provided that where the order appealed against is not uploaded on the common portal, the appellant shall submit or upload, as the case may be, a self-certified copy of the said order within a period of seven days from the date of filing of FORM GST APL-05 and a final acknowledgement, indicating appeal number, shall be issued 10[in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of issue of the provisional acknowledgment shall be considered as the date of filing of appeal:

Provided further that where the said self-certified copy of the order is submitted or uploaded after a period of seven days from the date of filing of FORM GST APL-05, a final acknowledgement, indicating appeal number, shall be issued 10[in Part B of FORM GST APL-02A] on removal of defects, if any, and the date of submission or uploading of such self-certified copy shall be considered as the date of filing of appeal.

Explanation.—For the purposes of this rule, the appeal shall be treated as filed only when the final acknowledgement, indicating the appeal number, is issued.

(5) The fees for filing of appeal or restoration of appeal shall be one thousand rupees for every one lakh rupees of tax or input tax credit involved or the difference in tax or input tax credit involved or the amount of fine, fee or penalty determined in the order appealed against, subject to a maximum of twenty five thousand rupees and a minimum of five thousand rupees:

Provided that the fees for filing of an appeal in respect of an order not involving any demand of tax, interest, fine, fee or penalty shall be five thousand rupees.(6) There shall be no fee for application made before the Appellate Tribunal for rectification of errors referred to in sub-section (10) of section 112.]

1. Substituted vide Notification No. 12/2024-CT dated 10.07.2024. for "Rule 110. Appeal to the Appellate Tribunal.-

(1) An appeal to the Appellate Tribunal under subsection (1) of section 112 shall be filed along with the relevant documents either electronically or otherwise as may be notified by the Registrar, in FORM GST APL-05 , on the common portal and a provisional acknowledgement shall be issued to the appellant immediately.

(2) A memorandum of cross-objections to the Appellate Tribunal under sub-section (5) of section 112 shall be filed either electronically or otherwise as may be notified by the Registrar, in FORM GST APL-06 .

(3) The appeal and the memorandum of cross objections shall be signed in the manner specified in rule 26.

(4) A certified copy of the decision or order appealed against along with fees as specified in sub-rule (5) shall be submitted to the Registrar within seven days of the filing of the appeal under sub-rule (1) and a final acknowledgement, indicating the appeal number shall be issued thereafter in FORM GST APL-02 by the Registrar:

Provided that where the certified copy of the decision or order is submitted within seven days from the date of filing the FORM GST APL-05 ,the date of filing of the appeal shall be the date of the issue of the provisional acknowledgement and where the said copy is submitted after seven days, the date of filing of the appeal shall be the date of the submission of such copy.

Explanation. -For the purposes of this rule, the appeal shall be treated as filed only when the final acknowledgement indicating the appeal number is issued.

(5) The fees for filing of appeal or restoration of appeal shall be one thousand rupees for every one lakh rupees of tax or input tax credit involved or the difference in tax or input tax credit involved or the amount of fine, fee or penalty determined in the order appealed against, subject to a maximum of twenty-five thousand rupees.

(6) There shall be no fee for application made before the Appellate Tribunal for rectification of errors referred to in sub-section (10) of section 112."

7. Inserted (w.e.f. 22.09.2025) by Notification No. 13/2025 - CT dated 17.09.2025.

8. Omitted (w.e.f. 22.09.2025) "Provided that an appeal to the Appellate Tribunal may be filed manually in FORM GST APL-05, along with the relevant documents, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order, and in such case, a provisional acknowledgement shall be issued to the appellant immediately." by Notification No. 13/2025 - CT dated 17.09.2025.

9. Omitted (w.e.f. 22.09.2025) "Provided that the memorandum of cross-objections may be filed manually in FORM GST APL-06, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order." by Notification No. 13/2025 - CT dated 17.09.2025.

10. Substituted (w.e.f. 22.09.2025) by Notification No. 13/2025 - CT dated 17.09.2025.

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.

Electronic appeal filing 110(1)

Questions to answer on the file3 questions
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Provisional Tribunal acknowledgement 110(1)

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Electronic cross objections 110(2)

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Final Tribunal acknowledgement 110(4)

Questions to answer on the file4 questions
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Timely copy for unavailable Tribunal order 110(4) first proviso

Questions to answer on the file5 questions
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Tribunal deemed filing date 110(4)

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Tribunal treatment as filed 110(4) Explanation

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Ordinary appeal or restoration fee scale 110(5)

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Fee basis needing interpretation 110(5)

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No-demand appeal fee 110(5) proviso

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Rectification application has no fee 110(6)

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Amendment history

The CBIC text carries 5 footnotes. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]

Amendments to Rule 110 as footnoted in the CBIC text
NoteChange
1Substituted vide Notification No. 12/2024-CT dated 10.07.2024. for "Rule 110. Appeal to the Appellate Tribunal.-[2]
7Inserted (w.e.f. 22.09.2025) by Notification No. 13/2025 - CT dated 17.09.2025.[3]
8Omitted (w.e.f. 22.09.2025) "Provided that an appeal to the Appellate Tribunal may be filed manually in FORM GST APL-05, along with the relevant documents, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order, and in such case, a provisional acknowledgement shall be issued to the appellant immediately." by Notification No. 13/2025 - CT dated 17.09.2025.[3]
9Omitted (w.e.f. 22.09.2025) "Provided that the memorandum of cross-objections may be filed manually in FORM GST APL-06, only if the Registrar allows the same by issuing a special or general order to that effect, subject to such conditions and restrictions as specified in the said order." by Notification No. 13/2025 - CT dated 17.09.2025.[3]
10Substituted (w.e.f. 22.09.2025) by Notification No. 13/2025 - CT dated 17.09.2025.[3]
Provisions connected to Rule 110
ProvisionConnectionWords that tie them
Section 112 of the CGST Act, 2017this provision requires Section 112 of the CGST Act, 2017110(1) "sub-section (1) of section 112"
Rule 26this provision requires Rule 26110(3) "manner specified in rule 26"

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 (3)

NumberDateSubject
Notification No. 13/2025-Central Tax17 September 2025Seeks to notify the Central Goods and Services Tax (Third Amendment) Rules 2025.
Notification No. 12/2024-Central Tax10 July 2024Seeks to make amendments (Amendment, 2024) to the CGST Rules, 2017.
Notification No. 10/2017-Central Tax28 June 2017Seeks to amend CGST Rules notification no 3/2017-Central Tax dt 19.06.2017 amended by a later instrument

Unsettled questions

The words of Rule 110 do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.

  1. What interval satisfies immediately for provisional acknowledgement under Rules 108,109,110 and111 when issue is delayed?
  2. How does Rule 110(5) charge a fractional lakh, and which base applies where multiple tax, credit, difference, fine, fee or penalty limbs coexist?

See also

References

  1. Central Board of Indirect Taxes and Customs. "Rule 110. Appeal to the Appellate Tribunal". Central Goods and Services Tax Rules, 2017, CBIC tax information portal, with amendment footnotes 1 to 5. Retrieved 17 September 2026.
  2. Notification No. 12/2024-Central Tax, dated 10 July 2024: Seeks to make amendments (Amendment, 2024) to the CGST Rules, 2017. Cited in CBIC footnote 1.
  3. Notification No. 13/2025-Central Tax, dated 17 September 2025: Seeks to notify the Central Goods and Services Tax (Third Amendment) Rules 2025. Cited in CBIC footnotes 7, 8, 9 and 10.

External links