The Goods and Services Tax Appellate Tribunal (GSTAT) is a statutory second-tier appellate forum, established as a quasi-judicial institution under Section 109 of the Central Goods and Services Tax Act, 2017 (CGST Act). Its constitutional authority is derived from Article 323B of the Constitution of India, which permits the creation of tribunals for tax disputes. The GSTAT was conceived as an integral part of the GST architecture in 2017 to resolve disputes between taxpayers and the Central or State GST administration. Its purpose is to serve as the final fact-finding authority in GST matters, thereby reducing the burden on High Courts, which can only hear appeals from the GSTAT on a substantial question of law.
The GSTAT hears appeals under Section 112 of the CGST Act against orders passed by the First Appellate Authority (under Section 107) or the Revisional Authority (under Section 108). A key mechanism is the mandatory pre-deposit required to file an appeal, which was recently amended: the appellant must deposit 10% of the remaining disputed tax, subject to a cap of ₹20 crore for CGST. The Tribunal became formally operational on September 24, 2025, after remaining non-functional for over eight years due to legislative and judicial challenges regarding the appointment of members. This operationalisation was governed by the GSTAT (Procedure) Rules, 2025, notified on April 24, 2025. Recently, the GSTAT has undergone procedural changes, including the reconstitution of its Benches and a revised classification of cases into Category-I and Category-II, effective from August 1, 2026, to streamline case allocation and improve judicial efficiency.