GST Appellate Tribunal 2025: Resolving India’s Tax Disputes – IMPRI Impact And Policy Research Institute

Policy Updates
Sudeepti Joshi

Background

The introduction of the Goods and Services Tax (GST) in 2017 has brought the various central and state level indirect taxes under one unified indirect tax framework. However, the proliferation of the GST regime has also led to growing tax related disputes. Such disputes lead to ambiguity for the taxpayer, as well as cause additional burden on tax administration. Hence, a specialised appellate body was required for the successful implementation of GST

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Goods and Services Tax Appellate Tribunal (GSTAT)was established under Section 109 of Central Goods and Service Tax (CGST) Act, 2017 (Central Board of Indirect Taxes and Customs, 2020). It is an independent statutory body functioning as a second level of appeal against decisions between the taxpayer and tax authorities of the central Government or state Governments. It entertains appeals against orders passed by appellate or revisional authorities under CGST Act, 2017 under Section 107 and 108 respectively, and provides a common appellate forum for disputes.

However, the creation of GSTAT in law did not automatically make it a functioning appellate mechanism. The Tribunal still required institutional appointments, the constitution of benches, procedural rules, filing mechanisms, digital infrastructure and other operational arrangements before it could become fully functional. In other words, establishing the Tribunal through legislation was only the first step; it also had to be institutionally established and operationalised to effectively handle GST-related appeals.

In this context, 2025 marked a significant development for GSTAT. The notification of the GSTAT (Procedure) Rules, 2025, on 24 April 2025, brought the Tribunal closer to becoming a functional appellate body by laying down the procedures to be followed for appeals and other proceedings before it.

Functioning

A significant milestone in the operationalisation of GSTAT came in 2025 when Justice (Retd.) Sanjaya Kumar Mishra was appointed as the first President of the Tribunal, and was sworn in by Nirmala Sitharaman, the Finance Minister (PIB, 2024b). The appointment made the Tribunal a two-person headship body, and was another step towards its transition from being a mere statutory body to a well functioning appellate authority.

GSTAT was officially commissioned in New Delhi on 24th September 2025 (PIB, 2025c). The Tribunal is set up with the purpose to facilitate Tax payers with a remedy to sort out disputes arising from GST in a timely and efficient manner and to alleviate the load of cases at the higher judiciary. It would have the Principal Bench seated in Delhi and 31 State Benches across the country to make the appellate proceedings more accessible to the taxpayers (PIB, 2024a).

The Tribunal also has jurisdiction on anti-profiteering issues. At its 53rd meeting, the GST Council recommended the insertion of a provision in Section 109 of the CGST Act to empower the Principal Bench of GSTAT to adjudicate such cases. It also fixed April 1, 2025, as the sunset date for filing fresh anti-profiteering applications (PIB, 2024).

The GSTAT Chennai Bench became operational on 22nd January 2026, when its members were formally inducted in a ceremony marking the Bench’s establishment (PIB, 2026a). With this, the institutional framework envisaged under the CGST Act- a President, a Principal Bench, and functioning State Benches, had moved from statutory design into place.

Performance 

Prior to GSTAT’s establishment, taxpayers disputing GST orders had no dedicated appellate forum and were compelled to approach High Courts directly, contributing to prolonged litigation and a backlog that GSTAT’s own President described as “significant” at the Tribunal’s launch (PIB, 2025c). The reforms accompanying GSTAT’s rollout were designed specifically to address this bottleneck by easing the financial and procedural burden of filing an appeal.

At the 53rd GST Council Meeting, several such changes were approved (PIB, 2024):

Source: Press Information Bureau, 2024

By lowering the cash outlay required to contest a tax order and fixing monetary thresholds for departmental appeals, these changes were intended to reduce both the volume of low-value disputes reaching GSTAT and the cash-flow burden on taxpayers pursuing genuine appeals (PIB, 2024).

The first indication of these reforms being tested in practice came with the Chennai Bench’s first hearing, held shortly after its members were inducted (PIB, 2026b). As GSTAT is still in its early operational phase, official data on case outcomes or disposal rates is not yet available; this is an area worth tracking as more benches become active and a caseload record accumulates.

Impact

GSTAT has also been positioned as an extension of the overall development of the GST system. At the launch of the Tribunal, Finance Minister Nirmala Sitharaman remarked that the progress GST had made over its eight years was particularly significant. She also highlighted the role of GSTAT in building a robust institutional mechanism for resolving indirect tax disputes (PIB, 2025c). This situates GSTAT in a broader context of reform aimed at increasing consistency and predictability of the indirect tax regime rather than as another appellate authority.

For GSTAT’s President, Justice (Retd.) Sanjaya Kumar Mishra, one of the immediate priorities is to clear the growing backlog of GST appeals accumulated over the years (PIB, 2025c). At the same time, the Tribunal’s judgments are expected to contribute to greater consistency in future GST jurisprudence, providing taxpayers and tax authorities with greater certainty in interpreting provisions that have so far been subject to repeated litigation.

The growing importance attached to GSTAT has also been reflected in the government’s recent GST reforms. As part of the latest GST rate rationalisation, the operationalisation of GSTAT was identified as a key procedural reform aimed at the swift resolution of appeals and reducing litigation. It was placed alongside measures such as streamlined registration and provisional refund mechanisms, reflecting a broader effort by the government to simplify compliance and make the process of dispute resolution more efficient for taxpayers (PIB, 2025b).

The success of the reforms will rely largely on GSTAT’s ability to clear its backlog of cases and to be consistent in its decisions. If GSTAT manages these tasks efficiently, it will contribute greatly to expediting GST disputes and to minimizing the uncertainty that has plagued GST law from its very inception.

Emerging Issues

Staffing and Institutional Readiness

GSTAT’s initial rollout also showed that setting up the Tribunal involved more than notifying the Rules and inaugurating benches. The Department of Revenue had to separately invite applications for Judicial and Technical Members for the Principal Bench and State Benches (PIB, 2024a). This shows that filling the positions was an important part of making the Tribunal functional, especially since it had to deal with both new and pending appeals.

Scale of Recruitment Required

This staffing requirement is significant in scale. Each Bench is designed to comprise two Judicial Members, one Technical Member (Centre), and one Technical Member (State) (PIB, 2025c), meaning the 31 State Benches together require well over a hundred senior appointments nationwide. The minimum eligibility age for these posts is 50 years (PIB, 2024a), which narrows the pool of eligible candidates considerably. Recruiting and onboarding this many qualified appointees across the country in a short span is a distinct practical constraint on how quickly the Tribunal can become fully functional, separate from the question of whether posts are filled at all.

Taxpayer Awareness

The government also had to educate taxpayers on how the new mechanism would work in reality. To do so, taxpayer outreach webinars were held to inform taxpayers about the appeals process, for example, how to calculate pre-deposit amounts and the most commonly required documents (PIB, 2025a). This requirement of specific education suggests that taxpayers and practitioners had experienced practical problems in using the new appeal scheme at the initial phase. Together, these gaps, incomplete staffing, the scale of recruitment required, and limited taxpayer familiarity, indicate that GSTAT’s early challenges lay less in its legal design and more in the practical work of making it usable.

Uneven Pace of Bench Rollout

GSTAT’s benches have become operational at different times rather than all at once. The Chennai Bench, for instance, became operational only in January 2026, several months after the Principal Bench in Delhi was launched (PIB, 2026a). With 31 State Benches announced nationwide (PIB, 2024a), this staggered rollout raises the concern that variations in staff, facilities, and case-handling capacity across benches could result in taxpayers in different states experiencing very different speeds of access to the appellate process.

Dependence on Centre-State Cooperation

GSTAT’s functioning also depends on continued cooperation between the Centre and the States. Since GST is jointly managed by both levels of government, the Tribunal requires their cooperation in appointment, administration, and the implementation of decisions. The Minister of State for Finance, at the Tribunal’s launch, noted the importance of maintaining the “spirit of cooperation” between the Centre and States, a dependency that could become a vulnerability if that cooperation weakens once the initial launch attention fades (PIB, 2025c).

Way Forward

Accelerating and Standardising Recruitment

Given the scale of appointments required, over a hundred Judicial and Technical Members across 31 State Benches, the Department of Revenue could benefit from a standing, continuously updated panel of eligible candidates rather than initiating fresh recruitment cycles, bench by bench. This would help address both the staffing gap and the practical constraint posed by the narrow, 50-plus eligible candidate pool, allowing new benches to be staffed more quickly as they are notified.

Standardising Bench Capacity

To address the uneven pace of bench operationalisation, a clear, publicly tracked rollout schedule for the remaining State Benches, with defined staffing and infrastructure benchmarks each bench must meet before being declared operational, would help ensure that taxpayers across states face comparable wait times rather than an ad hoc sequence of launches. Prioritising benches in states with the largest pending caseloads could also help direct capacity to where it is needed most.

Institutionalising Centre-State Coordination

Rather than relying on goodwill alone, GSTAT’s dependence on Centre-State cooperation could be reduced by embedding a formal coordination mechanism, for instance, a standing GST Council review of GSTAT’s staffing and administrative needs at regular intervals, similar to the Council’s existing role in GST rate and policy matters. This would give Centre-State cooperation an institutional channel to work through, rather than leaving it contingent on the level of political goodwill at any given time.

Ensuring Consistency Across Benches

Beyond staffing and coordination, GSTAT’s longer-term credibility will depend on the consistency of its rulings across 31 independently operating State Benches. Differing interpretations of the same legal question across states could recreate the very unpredictability the Tribunal was meant to resolve. The President’s existing power to constitute a Larger Bench to resolve conflicting decisions offers a starting mechanism, but its use may need to be applied proactively, tracking divergent rulings across benches, rather than only when a conflict is formally escalated.

Selected References and Important Links

Ministry of Finance. (2019, March 21). Cabinet approves creation of the National Bench of the Goods and Services Tax Appellate Tribunal (GSTAT) [Press release]. Press Information Bureau, Government of India. 

https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1561067

Ministry of Finance. (2020, September 30). The Central Goods and Services Tax Act, 2017 (as amended). Central Board of Indirect Taxes and Customs, Government of India. 

https://cbic-gst.gov.in/pdf/CGST-Act-Updated-30092020.pdf

Ministry of Finance. (2024, June 21). Recommendations of 53rd GST Council Meeting [Press release]. Press Information Bureau, Government of India.

https://www.pib.gov.in/PressReleaseIframePage.aspx?PRID=2027982

Ministry of Finance. (2024, August 2). Department of Revenue, Ministry of Finance, invites applications for appointment to the posts of the Judicial Members, Technical Members (Centre) and Technical Member (State) in Principal Bench and States Benches of GST Appellate Tribunal [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2006346

Ministry of Finance. (2024, September). Union Finance Minister Smt. Nirmala Sitharaman administers Oath of Office to Justice (Retd.) Sanjaya Kumar Mishra as the first President of GST Appellate Tribunal in New Delhi [Press release]. Press Information Bureau, Government of India. 

https://www.pib.gov.in/PressReleaseIframePage.aspx?PRID=2019749

Ministry of Finance. (2025, March 6). DGTS Mumbai & Maharashtra National Law University, Mumbai organise webinar on GST appeal procedures [Press release]. Press Information Bureau, Government of India

. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2271272&reg=3&lang=2

Ministry of Finance. (2025, September). Next-Gen GST overhaul: Staple foods tax-free, processed foods at 5% — Big relief for consumers and small businesses [Press release]. Press Information Bureau, Government of India.

https://www.pib.gov.in/PressReleasePage.aspx?PRID=2164586&reg=48&lang=2

Ministry of Finance. (2025, September 24). Union Minister of Finance and Corporate Affairs Smt. Nirmala Sitharaman launches Goods and Services Tax Appellate Tribunal (GSTAT) in New Delhi [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2170932&reg=3&lang=2

Ministry of Finance. (2026, January 22). Hon’ble members assume charge at GSTAT, Chennai Bench [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2217217&reg=3&lang=2

Ministry of Finance. (2026, June 25). GSTAT Chennai Bench commences first hearing [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2277279&reg=48&lang=2

About The Contributor

Sudeepti Joshi is an undergraduate student pursuing a B.A. (Hons.) in Economics at Dyal Singh College, University of Delhi. Her interests lie at the intersection of economics, public policy and development.

Acknowledgements

The author extends sincere gratitude to Madhuritha D, Kavin Adithya CB and the IMPRI team for their expert guidance and constructive feedback throughout the process.

Disclaimer

This article is intended for academic purposes only. The views expressed are those of the author and do not necessarily reflect the views of IMPRI or any government institution.

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