A significant and practical update has been introduced on the GST portal regardingĀ pre-deposit while filing appealsunder GST. This change directly impacts taxpayers filing appeals inĀ Form APL-01Ā and resolves long-standing practical difficulties.
š Background ā What is Pre-deposit under GST?
As per Section 107(6) of the CGST Act, 2017, any taxpayer filing an appeal before the Appellate Authority is required to make a mandatory pre-deposit, which includes:
- ā Ā Full payment of admitted tax liability, and
- ā Ā 10% of disputed tax amountĀ (subject to maximum limits)
This pre-deposit is a pre-condition for admission of appeal.
ā ļø Issue Faced Earlier on GST Portal
Earlier, while filing Form APL-01, the GST portal:
- Auto-populatedĀ 10% pre-deposit
- ā Field wasĀ non-editable
This created practical challenges such as:
ā Common Problems
- Pre-deposit already paid throughĀ DRC-03 or other mode
- IncorrectĀ demand reflected under wrong head
- Partial payments already made butĀ not considered
- Cases involvingĀ interest/penalty disputes only
- Situations whereĀ different interpretation of disputed amount
š Result: Taxpayers were forced into incorrect calculations or duplication of payments.
ā New Update (Effective 6 April 2026)
GSTN has now introduced a major relief:
š¹ Key Change:
š Pre-deposit percentage field is now EDITABLE in Form APL-01
šÆ What This Means for Taxpayers
Now taxpayers can:
- āļø Modify pre-deposit percentage as per actual requirement
- āļø Adjust amount already paid
- āļø Avoid excess or duplicate payment
- āļø Ensure correct computation of disputed amount
- āļø Align appeal filing with actual facts of the case
š§¾ Practical Scenarios Where This Helps
1. Pre-deposit Already Paid
If taxpayer already paid via DRC-03, now:
- Can reduce payable amount in APL-01
2. Incorrect Demand Classification
- If system shows higher demand ā taxpayer can correct base
3. Appeal Only for Penalty/Interest
- No need to blindly apply 10% on total demand
4. Multiple Orders / Partial Appeals
- Flexibility to compute pre-deposit proportionately
āļø Important Safeguard
š This flexibility is not absolute.
- TheĀ Appellate Authority will verify:
- Correctness of pre-deposit amount
- Mode of payment
- Compliance with Section 107(6)
ā ļø Any incorrect adjustment may lead to:
- Appeal rejection
- Deficiency memo
- Additional demand
š Key Takeaways for Professionals
- š¹ Always computeĀ disputed tax correctly
- š¹ EnsureĀ proper documentation of earlier payments
- š¹ Maintain reconciliation between:
- Order amount
- Paid amount
- Pre-deposit requirement
š” Professional Tip (Important)
Before editing pre-deposit:
š Prepare a working sheet including:
- Total demand
- Admitted liability
- Disputed portion
- Pre-deposit calculation
- Payments already made
This avoids litigation risk at appellate stage.
š Conclusion
This update is a practical and taxpayer-friendly reform by GSTN. It removes rigid system limitations and aligns portal functionality with real-life scenarios.
š However, with flexibility comes responsibility ā accurate computation and proper justification are now more important than ever.
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