A significant and practical update has been introduced on the GST portal regarding pre-deposit while filing appealsunder GST. This change directly impacts taxpayers filing appeals in Form APL-01 and resolves long-standing practical difficulties.
🔍 Background – 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:
- ✅ Full payment of admitted tax liability, and
- ✅ 10% of disputed tax amount (subject to maximum limits)
This pre-deposit is a pre-condition for admission of appeal.
⚠️ Issue Faced Earlier on GST Portal
Earlier, while filing Form APL-01, the GST portal:
- Auto-populated 10% pre-deposit
- ❌ Field was non-editable
This created practical challenges such as:
❗ Common Problems
- Pre-deposit already paid through DRC-03 or other mode
- Incorrect demand reflected under wrong head
- Partial payments already made but not considered
- Cases involving interest/penalty disputes only
- Situations where different interpretation of disputed amount
👉 Result: Taxpayers were forced into incorrect calculations or duplication of payments.
✅ New Update (Effective 6 April 2026)
GSTN has now introduced a major relief:
🔹 Key Change:
👉 Pre-deposit percentage field is now EDITABLE in Form APL-01
🎯 What This Means for Taxpayers
Now taxpayers can:
- ✔️ Modify pre-deposit percentage as per actual requirement
- ✔️ Adjust amount already paid
- ✔️ Avoid excess or duplicate payment
- ✔️ Ensure correct computation of disputed amount
- ✔️ Align appeal filing with actual facts of the case
🧾 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 → 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
⚖️ Important Safeguard
👉 This flexibility is not absolute.
- The Appellate Authority will verify:
- Correctness of pre-deposit amount
- Mode of payment
- Compliance with Section 107(6)
⚠️ Any incorrect adjustment may lead to:
- Appeal rejection
- Deficiency memo
- Additional demand
📌 Key Takeaways for Professionals
- 🔹 Always compute disputed tax correctly
- 🔹 Ensure proper documentation of earlier payments
- 🔹 Maintain reconciliation between:
- Order amount
- Paid amount
- Pre-deposit requirement
💡 Professional Tip (Important)
Before editing pre-deposit:
👉 Prepare a working sheet including:
- Total demand
- Admitted liability
- Disputed portion
- Pre-deposit calculation
- Payments already made
This avoids litigation risk at appellate stage.
🚀 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.
👉 However, with flexibility comes responsibility — accurate computation and proper justification are now more important than ever.
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