With the June 30 deadline for filing legacy appeals before the Goods and Services Tax Appellate Tribunal (GSTAT) fast approaching, tax professionals, chartered accountants and industry bodies have urged the Finance Ministry to extend the filing window, warning that persistent technical glitches on the GSTAT portal could prevent thousands of taxpayers from filing their appeals before the deadline. The demand comes as taxpayers seek to file appeals arising from nearly nine years of litigation accumulated during the period when the Tribunal remained non-operational. Experts said the combination of a massive backlog, voluminous documentation and continuing portal-related issues has significantly constrained taxpayers’ ability to meet the deadline.According to Aditya Singhania, Founder of Trackase,the backlog is estimated at nearly four lakh to 4.5 lakh legacy appeals, while only around 36,929 appeals have been filed nationwide so far.”The ground reality is deeply concerning. Against an anticipated backlog of nearly four to four and a half lakh appeals accumulated over nine years of the Tribunal’s non-operationality, only around 36,929 appeals have been filed nationally as of now,” Singhania said.He attributed the slow pace of filings to the teething troubles of the newly launched e-filing portal, including server time-outs, authentication challenges, payment gateway reconciliation issues and a filing structure that requires considerable time and effort to navigate.Experts cite portal hurdles, record backlogAccording to experts and representations submitted to the Finance Ministry, taxpayers continue to face multiple technical issues on the GSTAT portal, including session expiry, repeated login failures, Aadhaar authentication problems, Digital Signature Certificate (DSC) validation failures, payment reconciliation delays and incomplete integration between the Goods and Services Tax Network (GSTN) and the GSTAT portal.Experts said taxpayers are also required to retrieve and compile extensive records accumulated over several years, including adjudication orders, invoices, reconciliations, e-way bills, ledger extracts and other supporting documents, making the filing process particularly time-consuming.CA Nitin Bansal, State President, BJP CA Cell Haryana, said the Finance Ministry has received several representations highlighting the practical challenges taxpayers are facing in filing appeals before the Tribunal. “With the Tribunal becoming operational after nearly nine years, taxpayers must now prepare and file a substantial backlog of appeals within a limited window, many involving voluminous, multi-year records, even as the GSTAT e-filing portal continues to stabilise,” Bansal said.He added that extending the deadline would be revenue-neutral as the mandatory pre-deposit and other statutory conditions would remain unchanged while ensuring genuine taxpayers are not denied their appellate remedy because of circumstances beyond their control.One-time extension soughtCA Sonu Goel, Chairman, Panipat Branch of the Institute of Chartered Accountants of India (ICAI),said a one-time extension would ensure disputes are decided on their merits rather than procedural constraints.”One-time extension would safeguard taxpayers’ right to appeal, uphold the principles of natural justice, and ensure that disputes are decided on merits rather than being defeated by procedural or technological constraints. This pragmatic relief would further reinforce the Government’s commitment to ease of doing business while maintaining certainty and confidence in the GST ecosystem,” Goel said.Parag Mehta, Partner at N. A. Shah Associates LLP,said the portal continues to experience issues ranging from login failures and incorrect fee calculations to disappearing data.”Considering the fact that the portal is not fully supporting the filing process and the number of appeals filed remains significantly lower than expected, the deadline should be extended. GSTAT is an important appellate remedy and taxpayers should not be deprived of that opportunity,” Mehta said.Bar association flags nationwide concernsThe Sales Tax Bar Association has also written to the Finance Ministry seeking an extension of the filing deadline, stating that taxpayers and tax professionals across the country continue to face significant practical and technical difficulties while filing appeals through the GSTAT portal.In its representation, the association said the present limitation period covers appellate orders accumulated over nearly nine years when the Tribunal remained non-functional, requiring taxpayers to retrieve historical records and prepare detailed documentation within a limited period.The association highlighted recurring issues including server interruptions, repeated Aadhaar authentication and DSC validation failures, payment gateway reconciliation delays, manual duplication of information already available on the GSTN portal and challenges in uploading voluminous records.It warned that if the deadline is not extended, thousands of taxpayers could lose the opportunity to pursue their statutory appeals because of technological and procedural constraints, potentially leading to avoidable litigation before various High Courts.Prabhat Ranjan, Senior Director at Nexdigm,said extending the filing deadline has become “the need of the hour.””The appellate process should be about the actual merits of the issues between both parties and not technical questions of delay. This is a taxpayer-friendly measure that will make GST dispute resolution processes more fair and credible,” he said.As of publication, the government has not announced any extension of the June 30 deadline for filing legacy GSTAT appeals. While the GSTAT has extended the period for relaxed scrutiny of filed appeals until December 31, 2026, tax professionals, industry experts and representative bodies continue to seek a one-time extension of the filing deadline, arguing that additional time would enable taxpayers to exercise their statutory right of appeal without affecting revenue, as the mandatory pre-deposit requirements would continue to apply.
