The GST Network (GSTN) has introduced a significant improvement in the appeal filing process by enabling taxpayers to edit the pre-deposit percentage in Form APL-01, effective 6th April 2026. This update addresses long-standing practical issues faced during GST appeal filings.

Background

Under Section 107(6) of the CGST Act, 2017, filing an appeal before the First Appellate Authority requires:

• Full payment of admitted tax, and
• Pre-deposit of 10% of the disputed tax amount

Earlier, the GST portal auto-calculated and fixed the pre-deposit at 10%, without allowing any modification. This created difficulties where:

• Taxpayers had already deposited amounts during investigation or adjudication, or
• Payments were incorrectly classified under different heads

Key Update by GSTN

1. Editable Pre-Deposit Field Enabled

• Taxpayers can now edit the pre-deposit amount/percentage while filing Form APL-01
• Provides flexibility to reflect:
  • Actual payments already made
  • Correct computation of disputed tax

2. Effective Date

• This functionality is available from 6th April 2026 on the GST portal

3. Improved Accuracy in Appeal Filing

• Reduces duplication of payments
• Prevents excess or incorrect deposits
• Ensures alignment between books, challans, and portal data

Important Safeguard

Verification by Appellate Authority

• The Appellate Authority will verify:
  • Correctness of the pre-deposit amount
  • Nature and classification of payments
  • Compliance with Section 107(6)
• Any discrepancy may impact:
  • Admission of appeal
  • Further proceedings

Practical Implications for Taxpayers

• Greater flexibility in handling pre-deposit adjustments
• Ability to avoid unnecessary cash outflow
• Need for accurate reconciliation of payments before filing appeal

What Taxpayers Should Do

1. Reconcile Payment Records

• Verify:
  • Amounts paid during investigation (DRC-03)
  • Payments made against demand orders
  • Electronic cash/credit ledger balances

2. Compute Correct Pre-Deposit

• Ensure that:
  • Total deposit equals 10% of disputed tax (after adjusting prior payments)
  • Admitted liability is fully discharged

3. Maintain Documentation

• Keep supporting documents ready:
  • Challans
  • DRC-03 filings
  • Order copies

These may be required during appellate verification.

Key Takeaways

• GSTN has resolved a major practical issue in appeal filing
• Pre-deposit field in APL-01 is now editable and flexible
• However, compliance responsibility remains with the taxpayer
• Incorrect reporting may lead to rejection or delay in appeal

Conclusion

This update enhances ease of doing business by aligning the GST portal with real-world tax scenarios. While flexibility has increased, taxpayers must exercise due diligence to ensure accurate and compliant appeal filings.

For expert guidance on this topic, contact your tax professional today.