GST Appellate Tribunal Procedure Rules, 2025

The Hon'ble Ministry of Finance (Department of Revenue) has issued a comprehensive notification dated April 24, 2025 introducing the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025. This notification, published under G.S.R. 256(E), establishes the procedural framework for the functioning of the GST Appellate Tribunal, marking a significant development in GST litigation management.

Table of Contents

• Key Features of the GSTAT Procedure Rules

  • Effective Date and Scope

  • Administrative Structure

  • Appeal Filing and Processing

  • Procedural Safeguards

  • Court Proceedings

  • Special Provisions

• GSTAT Forms: A Complete Overview

• Fee Structure

• Practical Implications for Taxpayers and Practitioners

• Conclusion

• Relevant Sections

Key Features of the GSTAT Procedure Rules

Effective Date and Scope

The Rules have come into force on the date of their publication in the Official Gazette (April 24, 2025). They provide a comprehensive framework for regulating the procedures and functioning of the GST Appellate Tribunal.

Administrative Structure

• Principal Bench and State Benches: The Rules formalize the structure with a Principal Bench and multiple State Benches

• Working Hours: Regular sitting hours from 10:30 AM to 1:30 PM and 2:30 PM to 4:30 PM

• Office Hours: Administrative offices remain open from 9:30 AM to 6:00 PM

• Official Seal: Each Bench will maintain an official seal as specified by the President

Appeal Filing and Processing

• Electronic Filing: All appeals must be filed online on the GSTAT Portal

• Prescribed Format: Appeals must follow specific formatting requirements including proper cause title, paragraph numbering, and complete party information

• Documentation: Every appeal must be accompanied by a certified copy of the order appealed against

• Time Periods: The Rules provide for computation of time periods with provisions for extensions in certain circumstances

Procedural Safeguards

• Natural Justice: Multiple provisions ensure compliance with principles of natural justice

• Cross-Objections: Clear procedures for filing and handling cross-objections

• Recusal: Provisions for recusal of Members in cases of potential conflicts of interest

• Inherent Powers: The Tribunal retains inherent powers to make necessary orders for meeting the ends of justice

Court Proceedings

• Cause List: Daily cause list to be published before close of working hours each day

• Record Maintenance: Detailed protocols for court diaries, order sheets, and case records

• Hybrid Hearings: Provisions for both physical and electronic hearings

• Document Inspection: Procedures for inspection of records with appropriate safeguards

Special Provisions

• Additional Evidence: Mechanisms for production of additional evidence when necessary

• Translation Services: Provisions for translation of documents in languages other than English

• Examination of Witnesses: Detailed procedures for witness examination and cross-examination

• Electronic Mode: Specific provisions for electronic filing and processing of appeals

GSTAT Forms: A Complete Overview

The notification introduces several standardized forms to streamline the Tribunal's proceedings. Below are the key forms with their respective functions:

Form Number	Rule Reference	Purpose/Function
GSTAT FORM-01	Rule 29 & 49	Interlocutory Application to the Appellate Tribunal
GSTAT FORM-02	Rule 54	Order Sheet (for tracking appeal progress)
GSTAT FORM-03	Rule 67	Application for Inspection of Records
GSTAT FORM-04	Rule 72	Memorandum of Appearance for Representatives
GSTAT FORM-05	Rule 81	Certification for Deponents Unacquainted with Language
GSTAT FORM-06	Rule 84(3)	Summons Format for Document Production
GSTAT FORM-07	Rule 93	Format for Recording Witness Depositions
GSTAT FORM-08	Rule 95	Certificate of Discharge for Witnesses

Additionally, the Rules establish several registers to be maintained by the Tribunal:

Register Code	Rule Reference	Register Purpose
GSTAT CDR-01	Rule 38	Daily Cause List Format
GSTAT CDR-02	Rule 53 & 110	Court Diary for Tracking Proceedings
GSTAT CDR-03	Rule 59(a)	Register of Provisional Appeals
GSTAT CDR-04	Rule 59(b)	Register of Appeals
GSTAT CDR-05	Rule 59(c)	Register of Interlocutory Appeals
GSTAT CDR-06	Rule 71	Register of Inspection
GSTAT CDR-07	Rule 116	Register for Supreme Court Appeals
GSTAT CDR-08	Rule 116	Register for High Court Appeals

Fee Structure

The Rules also establish a comprehensive fee structure for various applications and services:

Service/Application	Fee Amount
Inspection of Records	₹5,000
Interlocutory Applications	₹5,000
Appeals to GSTAT	As per CGST/SGST/UTGST Rules 2017
Applications under other provisions	₹5,000
Certified Copy of Final Order (for non-parties)	₹5 per page

Practical Implications for Taxpayers and Practitioners

1. Digital Transformation: The Rules embrace digital technology with mandatory electronic filing, paving the way for more efficient litigation management.

2. Procedural Clarity: The detailed procedures provide greater certainty for litigants regarding timelines, documentation requirements, and hearing processes.

3. Representation Guidelines: Clear guidelines have been provided for authorized representatives, including dress code and professional conduct expectations.

4. Costs and Fees: The fee structure is now explicitly defined, allowing businesses to better estimate litigation costs.

5. Accessibility: Provisions for electronic hearings may improve access to justice, especially for litigants in remote areas.

Conclusion

The GST Appellate Tribunal (Procedure) Rules, 2025 represent a significant milestone in establishing a structured appellate mechanism for GST disputes. The comprehensive framework combines traditional judicial procedures with modern digital practices, potentially leading to more efficient dispute resolution.

These Rules are expected to provide much-needed clarity for businesses and tax practitioners on procedural aspects of GST litigation. As the Tribunal begins its operations under these Rules, stakeholders should familiarize themselves with these procedures to effectively navigate the appellate process.