GST Update: Appeals Now Allowed Against NIL/Zero Demand Orders

GSTN has removed an important portal restriction that was preventing taxpayers from filing appeals against demand orders showing “NIL” or “Zero” demand, even where the underlying GST liability remained disputed. The change was announced through the GSTN Advisory dated 7 September 2026.

What Was the Earlier Issue?

The difficulty generally arose where a taxpayer had paid tax, interest or penalty before issuance of the final demand order, while continuing to dispute the underlying liability.

In certain cases, the adjudication order consequently reflected NIL demand. The GST Portal treated the zero demand as leaving no amount available for dispute and prevented filing of Form GST APL-01. GSTN had acknowledged this problem in its earlier Advisory dated 3 April 2026 and advised affected taxpayers to seek rectification of the order as an interim solution.

What Has Changed from 7 September 2026?

As per the GSTN Advisory dated 7 September 2026:

• The portal validation restricting appeals against NIL or Zero demand orders has been removed.
• Taxpayers can now file an appeal in Form GST APL-01 even where the demand order reflects NIL or Zero demand, provided a dispute regarding the liability exists and payment was made before issuance of the demand order.
• Taxpayers experiencing technical difficulties while filing such appeals can raise a ticket with the GST Helpdesk.

This removes a significant procedural hurdle for taxpayers who had already discharged the amount but still wished to challenge the underlying determination of liability.

Appeal Timeline Under the CGST Act

Section 107(1) of the Central Goods and Services Tax Act, 2017 provides that a person aggrieved by a decision or order of an adjudicating authority may appeal to the prescribed Appellate Authority within three months from the date on which the decision or order is communicated.

Under Section 107(4), the Appellate Authority may allow a further period of one month where sufficient cause for the delay is established.

Form GST APL-01 is the prescribed form for an appeal to the Appellate Authority under Rule 108(1) of the CGST Rules, 2017.

What Should Taxpayers Do?

Taxpayers who were previously unable to appeal solely because their demand order showed NIL or Zero demand should review the relevant orders immediately. Where the liability remains disputed, they should evaluate filing Form GST APL-01 while keeping the statutory limitation period under Section 107 in mind.

Conclusion

The GSTN update of 7 September 2026 provides welcome procedural relief by ensuring that prior payment does not, by itself, create a portal barrier to challenging a disputed liability. Businesses with affected orders should review their cases promptly and take appropriate appellate action within the applicable timelines.