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Rule 112 of the CGST Rules, 2017

From the IndiaAuditLens Law Library

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

At a glance

Entitlement and conditions

  • 112(3)The adjudicating authority or its authorised officer must receive a reasonable opportunity to examine the evidence or document, cross-examine a witness, or produce rebuttal evidence or witnesses.

Bars, duties and time limits

  • 112(1)An appellant cannot introduce evidence beyond what was produced below unless an exception applies: wrongful refusal to admit it, sufficient cause preventing production of requested or relevant evidence, or an order made without sufficient opportunity to produce relevant evidence.
  • 112(2)The Appellate Authority or Tribunal must give written reasons before admitting additional evidence under these exceptions.

Procedure, powers and definitions

  • 112(4)The appellate body retains power to direct production of a document or examination of a witness to enable disposal of the appeal.
  • 112The law does not settle when evidence ought to have been admitted, what amounts to sufficient cause, or what makes the earlier opportunity sufficient and the examination or rebuttal opportunity reasonable.

Rule 112 restricts additional oral or documentary evidence in an appeal to specified circumstances involving refusal, sufficient cause or inadequate opportunity in the earlier proceedings. Admission requires written reasons and an opportunity for the adjudicating authority to examine or rebut the evidence. The rule preserves the appellate body’s own power to call for documents or examine witnesses to dispose of the appeal.[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 112, verbatim (show)

Rule 112. Production of additional evidence before the Appellate Authority or the Appellate Tribunal.-

(1) The appellant shall not be allowed to produce before the Appellate Authority or the Appellate Tribunal any evidence, whether oral or documentary, other than the evidence produced by him during the course of the proceedings before the adjudicating authority or, as the case may be, the Appellate Authority except in the following circumstances, namely:-

(a) where the adjudicating authority or, as the case may be, the Appellate Authority has refused to admit evidence which ought to have been admitted; or (b) where the appellant was prevented by sufficient cause from producing the evidence which he was called upon to produce by the adjudicating authority or, as the case may be, the Appellate Authority; or (c) where the appellant was prevented by sufficient cause from producing before the adjudicating authority or, as the case may be, the Appellate Authority any evidence which is relevant to any ground of appeal; or (d) where the adjudicating authority or, as the case may be, the Appellate Authority has made the order appealed against without giving sufficient opportunity to the appellant to adduce evidence relevant to any ground of appeal.

(2) No evidence shall be admitted under sub-rule (1) unless the Appellate Authority or the Appellate Tribunal records in writing the reasons for its admission.

(3) The Appellate Authority or the Appellate Tribunal shall not take any evidence produced under sub-rule (1) unless the adjudicating authority or an officer authorised in this behalf by the said authority has been allowed a reasonable opportunity-

(a) to examine the evidence or document or to cross-examine any witness produced by the appellant; or (b) to produce any evidence or any witness in rebuttal of the evidence produced by the appellant under sub-rule (1).

(4) Nothing contained in this rule shall affect the power of the Appellate Authority or the Appellate Tribunal to direct the production of any document, or the examination of any witness, to enable it to dispose of the appeal.

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.

Additional evidence exception 112(1)

Questions to answer on the file7 questions
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Written reasons for admission 112(2)

Questions to answer on the file2 questions
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Lower authority opportunity on evidence 112(3)

Questions to answer on the file6 questions
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Preserved appellate production power 112(4)

Questions to answer on the file3 questions
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Circulars and notifications

No circular or notification in the CBIC repository is recorded as citing this rule.

Unsettled questions

The words of Rule 112 do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.

  1. When ought evidence to have been admitted by the lower authority for Rule 112(1)(a), where no admissibility standard is stated here?
  2. What circumstances amount to sufficient cause preventing production of the identified evidence under Rule 112(1)(b) or(c)?
  3. What opportunity to adduce evidence is sufficient before the appealed order under Rule 112(1)(d)?
  4. What opportunity is reasonable for the adjudicating authority or its authorised officer to examine, cross-examine or rebut the selected evidence under Rule 112(3)?

See also

References

  1. Central Board of Indirect Taxes and Customs. "Rule 112. Production of additional evidence before the Appellate Authority or the Appellate Tribunal". Central Goods and Services Tax Rules, 2017, CBIC tax information portal. Retrieved 17 September 2026.

External links