A.1 Why this Part comes first

Sections 109 to 121, CGST Act, 2017. Law stated as at 10 August 2026.

The GSTAT (Procedure) Rules, 2025 are procedure and nothing but procedure. Read alone, they will tell a practitioner how to lay out an appeal, how many copies to file, what the Registry does with it and how the order comes back. They will not tell him whether the appeal lies, when it must be filed, what must be paid before it is filed, or what the Tribunal can do with it once it is heard.

All of that is in the Act. A reader who studies only the Rules will file a perfectly formatted appeal that is time-barred, unpaid, and possibly not maintainable at all.

This Part is the frame the Rules sit inside. Every statement in it has been checked against the bare provision as reproduced with amendment footnotes in two ICAI compilations: the Background Material on GST, Volume II (ss.109–121), recorded at corpus/section-112-verified.md; and the April 2026 bare-law compilation for the September 2025 amendments and the CGST Rules, recorded at corpus/cgst-appeal-rules-verified.md. Where the two differ the later edition governs, and it does differ — on penalty-only pre-deposit, on the appeal fee, and on single-member competence. Where a figure appears in this Part it is the Act's figure. No figure in this book is taken from the Rules, because the Rules do not contain any, with the single exception of the Schedule of Fees discussed at r.119.

Three propositions govern the whole Part, and it is worth fixing them before the detail:

1. Nothing in G.S.R. 256(E) creates, extends or forgives a limitation period. The periods are in s.112. The power to condone is s.112(6). Rules 14 and 107 look like extension powers and are not — they reach time appointed by the Rules or by an order of the Tribunal, never the statutory period for instituting the appeal.
2. The Tribunal's procedural powers come from s.111, not from the Rules. The Rules are made under s.111 read with s.114 and are an exercise of a power the section already confers. Where the Rules are silent, the Tribunal is not disabled: s.111(1) gives it power to regulate its own procedure, and r.10 and r.123 are the domestic expression of that.
3. Two of the Act's own periods are shorter or longer than the Rules assume. Section 113(3) allows rectification within three months; r.108(2) allows a party one month. Section 113(2) caps adjournments at three per party; no rule in G.S.R. 256(E) repeats the cap. Both are worked below.