# First appeal to Appellate Authority (s.107, APL-01): how to reply

Appeal against any order under GST

## Section and form names

- Sections: 107
- Forms: APL-01, GST APL-01, FORM GST APL-01

## Time limit to reply

90 days from service. Set by the statute or rules; counted from service.

Unverified: this time limit is to be confirmed against the notified text.

3 months (taken as 90 days) from communication of the order, plus 1 month condonable under s.107(4)

## Reply form

[FORM GST APL-01: Appeal to Appellate Authority](https://charterai.in/notice/form/gst-apl01), filed through GST portal: APL-01 with Annexure.

Fields:
- 1. GSTIN / Temporary ID / UIN (filled from the notice and your records)
- 2. Legal name of the appellant (filled from the notice and your records)
- 3. Trade name, if any (filled from the notice and your records)
- 4. Address (filled from the notice and your records)
- 5. Order no. (filled from the notice and your records)
- 5. Order date (filled from the notice and your records)
- 6. Designation and address of the officer passing the order appealed against (filled from the notice and your records)
- 7. Date of communication of the order appealed against (filled from the notice and your records)
- 8. Name of the authorized representative (filled from the notice and your records)
- 9(i). Brief issue of the case under dispute (written in the reply)
- 9(ii). Description and classification of goods / services in dispute (filled from the notice and your records)
- 9(iii). Period of dispute (filled from the notice and your records)
- 9(iv). Amount under dispute: Tax / Cess (filled from the notice and your records)
- 9(iv). Amount under dispute: Interest (filled from the notice and your records)
- 9(iv). Amount under dispute: Penalty (filled from the notice and your records)
- 10. Whether the appellant wishes to be heard in person (filled from the notice and your records)
- 11. Statement of facts (written in the reply)
- 12. Grounds of appeal (written in the reply)
- 13. Prayer (written in the reply)
- 14. Amount of demand created (A): total (filled from the notice and your records)
- 14. Amount of demand admitted (B): total (filled from the notice and your records)
- 14. Amount of demand disputed (C): total (filled from the notice and your records)
- 15(a). Payment required: admitted amount (filled from the notice and your records)
- 15(a). Payment required: pre-deposit (10% of disputed tax) (filled from the notice and your records)
- 15(a). Total payment required before filing (filled from the notice and your records)
- 15(b). Admitted amount paid: debit entry no. (filled from the notice and your records)
- 15(b). Pre-deposit paid (filled from the notice and your records)
- 15(b). Pre-deposit: debit entry no. (filled from the notice and your records)
- 16. Whether appeal is being filed after the prescribed period (filled from the notice and your records)
- 17(a). Period of delay (filled from the notice and your records)
- 17(b). Reasons for delay (written in the reply)
- Verification: name (filled from the notice and your records)
- Verification: designation or status (filled from the notice and your records)
- Verification: place (filled from the notice and your records)
- Verification: date (filled from the notice and your records)

## What the reply must include

- jurisdictional/procedural grounds ahead of the merits
- statement of facts kept separate from the grounds of appeal
- numbered grounds of appeal, one assertion of error per ground
- 10% pre-deposit computation per tax head via PMT-06 from the cash ledger
- verification clause

## Reply outline

Structure strictly: jurisdictional/procedural grounds first, statement of facts as a separate chronological narrative (not argument), then numbered grounds of appeal, one assertion of error per ground, against each head of demand, with without-prejudice quantum alternatives. Compute the mandatory 10% pre-deposit per tax head (CGST/SGST/IGST), capped at ₹20 crore, and confirm it is paid via PMT-06 from the electronic cash ledger, not the credit ledger, which the portal rejects. Close with a signed verification clause.

- Jurisdictional and procedural grounds: Jurisdictional/procedural defects raised first, ahead of the merits.
- Statement of facts: Chronological narrative of the proceedings leading to the order appealed against.
- Grounds of appeal: One assertion of error per ground, merits ground-by-ground for each head of demand, then without-prejudice quantum alternatives.
- Pre-deposit computation: 10% of the disputed tax per tax head (CGST/SGST/IGST), capped at ₹20 crore, paid from the electronic cash ledger via PMT-06 (s.107(6)).
- Verification: Verification clause signed by the authorised signatory.
- Prayer: Request the order appealed against be set aside or modified as per the grounds.

## Related law

- [Section 107, CGST Act, 2017](https://charterai.in/law/cgst-act-2017/107)

## FAQ

### What is a First appeal to Appellate Authority (s.107, APL-01)?

Appeal against any order under GST

### What is the time limit to reply to a First appeal to Appellate Authority (s.107, APL-01)?

90 days from service. To be confirmed against the notified text. Set by the statute or rules; counted from service.

### How is the reply to a First appeal to Appellate Authority (s.107, APL-01) filed?

On FORM GST APL-01: Appeal to Appellate Authority, through GST portal: APL-01 with Annexure.

### What should the reply include?

Jurisdictional/procedural grounds ahead of the merits; Statement of facts kept separate from the grounds of appeal; Numbered grounds of appeal, one assertion of error per ground; 10% pre-deposit computation per tax head via PMT-06 from the cash ledger; Verification clause.

Draft this reply: https://charterai.in/sign-up

Canonical: https://charterai.in/notice/gst-first-appeal-to-appellate-authority-s-107-apl-01
