Part O.1 — Practice annexures
Part O.1 — Limitation ready-reckoner
Every period that bites on a GSTAT appeal, computed under r.3. Law stated as at 10 August 2026.
⚠️ Not one of these periods is fixed by the GSTAT (Procedure) Rules, 2025. The Rules supply only the method of counting (r.3). The periods themselves are in the CGST Act, and the internal periods are fixed by the Rules but run from events the Act controls. Where a notified date under s.112(1)/(3) is in play, take the notification from the Gazette — not from commentary.
O.1.1 The periods
Getting into the Tribunal
| # | What | Period | Runs from | Source | Extendable? |
|---|---|---|---|---|---|
| 1 | Taxpayer's appeal, order communicated on or after 1 Apr 2026 | 3 months | Communication of the s.107/s.108 order | s.112(1); S.O. 4220(E) | Yes — s.112(6), a further 3 months; whether that cap is absolute is contested, Part P, P7 |
| 1a | Taxpayer's appeal, order communicated before 1 Apr 2026 | until 30 June 2026 | a single notified date for the whole backlog | s.112(1); S.O. 4220(E) dated 17.09.2025 | as above. Any extension of 30 June 2026 is unverified |
| 2 | Departmental application | 6 months | The date the order was passed, or the notified date, whichever is later | s.112(3), (4) | Yes — s.112(6), a further 3 months |
| 3 | Cross-objections | 45 days | Receipt of notice that an appeal has been preferred | s.112(5) | Yes — s.112(6), a further 45 days |
Note the asymmetry at rows 1 and 2. The taxpayer's clock starts on communication; the department's starts when the order was passed, and runs twice as long.
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