GST Appeal Against NIL Demand Now Allowed on GST Portal

Introduction

The Goods and Services Tax Network (GSTN) has introduced a portal-level update allowing eligible taxpayers to file appeals against GST demand orders where the demand amount is reflected as “NIL” or “Zero”.

Through GSTN Advisory No. 671 dated 7 September 2026, GSTN has removed the previous portal validation that restricted taxpayers from filing appeals against such demand orders. The update applies to cases where a dispute regarding liability exists, the demand amount in the order is shown as NIL or Zero, and payment was already made by the taxpayer before issuance of the demand order.

The update enables eligible taxpayers to file an appeal through Form GST APL-01 against such demand orders.

This change is a GST Portal functionality update and does not amend the statutory provisions governing GST appeals. The right and procedure for filing appeals continue to be governed by the applicable provisions of GST law.

Businesses dealing with GST notices, demand orders, and compliance issues can also seek professional support through GST Compliance.

Earlier Issue With GST Appeal Against NIL Demand Orders

Before this update, taxpayers faced difficulty while filing a GST appeal against NIL demand orders on the GST Portal.

The issue generally occurred in cases where:

• The taxpayer paid tax, interest, or penalty during the proceedings;
• The payment was made before issuance of the demand order;
• The taxpayer did not accept the underlying liability;
• The final demand order reflected NIL or Zero outstanding demand.

In such situations, although the taxpayer had already made payment, a dispute regarding the tax liability or findings recorded in the order could still exist.

However, since the GST Portal reflected the demand amount as zero, the system validation restricted filing of Form GST APL-01.

This created a practical difficulty because the taxpayer could still dispute:

• The tax liability determined by the authority;
• The interpretation of GST provisions;
• The findings recorded in the demand order.

Therefore, a zero outstanding demand did not necessarily mean that there was no legal dispute.

Businesses facing GST proceedings should carefully review their case details and supporting documents through appropriate GST Notice Reply Services.

What Changed Under GSTN Advisory No. 671?

GSTN has now removed the earlier validation restricting appeal filing in eligible NIL or Zero demand cases.

As per GSTN Advisory 671, where:

• A dispute regarding liability exists;
• The demand order reflects “NIL” or “Zero” demand;
• Payment was made by the taxpayer before issuance of the demand order;

the taxpayer is now enabled to file an appeal through Form GST APL-01 on the GST Portal.

The update only removes the technical restriction on the portal and allows taxpayers to access the existing appellate process.

It does not create a new statutory right of appeal or change the provisions relating to GST appeals.

Can a Taxpayer File GST Appeal Against NIL or Zero Demand Orders?

Yes, taxpayers facing the specific situation covered under GSTN Advisory 671 can now file an appeal through Form GST APL-01.

However, this facility does not mean that every NIL or Zero demand order is automatically appealable.

The taxpayer must evaluate whether:

• A dispute regarding liability exists;
• The order contains findings that are being challenged;
• The case falls within the situation addressed by the GSTN update.

The portal facility only enables filing of the appeal. The legal grounds, maintainability, and outcome depend on the facts and circumstances of each case.

NIL Demand Does Not Always Mean Acceptance of Liability

A NIL or Zero demand order only indicates that no amount remains payable as outstanding demand.

It does not always mean that the taxpayer accepts the liability determined during proceedings.

For example, a taxpayer may make payment during the investigation or show cause notice stage without admitting that the tax liability is legally correct.

Therefore: Zero outstanding demand ≠ Acceptance of tax liability

The taxpayer may still challenge:

• The determination of liability;
• The legal interpretation adopted;
• The findings recorded in the order.

The latest GSTN update ensures that eligible taxpayers are not prevented from accessing the appeal mechanism only because the demand amount is reflected as NIL or Zero on the portal.

GST APL-01 NIL Demand Filing Facility

Form GST APL-01 is the prescribed form for filing an appeal before the Appellate Authority against an order passed under GST law.

With the latest update, eligible taxpayers can now file a GST APL-01 NIL demand appeal where:

• The demand amount shown in the order is NIL or Zero;
• Payment was already made before issuance of the order;
• The taxpayer continues to dispute the liability.

Earlier, the GST Portal validation restricted such appeal filing because the system considered that no demand amount was available for dispute.

After removal of the validation, eligible taxpayers can proceed with filing their appeal electronically.

Legal Framework for GST Demand Order Appeal

A GST demand order appeal continues to be governed by the existing appellate provisions under the CGST Act and Rules.

Section 107 of CGST Act, 2017

Section 107 of the CGST Act, 2017 provides the statutory mechanism for filing an appeal before the Appellate Authority against specified orders passed under GST law.

Rule 108 of CGST Rules, 2017

Rule 108 of the CGST Rules, 2017 prescribes the procedure for filing an appeal electronically through the prescribed form.

The latest GSTN Advisory 671 does not introduce a new right of appeal. It only removes the portal-level validation that earlier prevented eligible taxpayers from filing appeals in specific cases where the demand order reflected NIL or Zero demand.

Who Can Benefit From This GST Portal Update?

The facility is relevant for taxpayers who fall within the specific situation addressed under GSTN Advisory 671.

These taxpayers generally include those who:

• Received a GST demand order showing NIL or Zero demand;
• Had already made payment before issuance of the demand order;
• Continue to dispute the tax liability or findings recorded in the order.

For example, a taxpayer may have paid tax, interest, or penalty during proceedings without accepting the underlying liability. If the subsequent demand order reflects NIL or Zero demand, the taxpayer can now access the appeal filing facility through Form GST APL-01, subject to applicable legal requirements.

Taxpayers should evaluate the facts of each case before filing an appeal because the portal facility only enables filing and does not determine the merits of the dispute.

Impact of GSTN Advisory 671 on Taxpayers

The GSTN update addresses a practical difficulty faced by businesses while filing appeals against NIL or Zero demand orders.

Earlier, taxpayers could face a situation where:

• Payment was already made;
• The demand order reflected NIL or Zero demand;
• The taxpayer wanted to challenge the liability determination;
• The GST Portal restricted filing of Form GST APL-01.

The removal of this validation allows eligible taxpayers to proceed with the existing appellate mechanism.

This update is particularly relevant for businesses involved in:

• GST demand proceedings;
• Tax liability disputes;
• Adjudication orders;
• GST compliance reviews.

Businesses should maintain proper GST records and complete timely compliance through GST Return Filing Services to reduce future compliance risks.

Steps to File GST Appeal Against NIL Demand

Taxpayers facing eligible cases should follow these steps:

1. Review the Demand Order

Taxpayers should first examine:

• The demand order issued by the authority;
• Payment records;
• Grounds on which the liability is being disputed.

2. Verify Applicability of GSTN Update

The taxpayer should confirm whether the case falls within the NIL or Zero demand situation covered under GSTN Advisory No. 671.

The update applies where:

• A dispute regarding liability exists;
• The demand amount is reflected as NIL or Zero;
• Payment was made before issuance of the demand order.

3. Prepare Appeal Documents

The taxpayer should keep relevant documents ready, including:

• Copy of the demand order;
• Grounds of appeal;
• Supporting documents;
• Payment details;
• Other relevant records.

4. File Form GST APL-01

The appeal should be filed electronically through the GST Portal using Form GST APL-01 as per the applicable appeal procedure.

5. Monitor Appeal Proceedings

After filing the appeal, taxpayers should track further communications from the Appellate Authority and provide additional information wherever required.

What Should Businesses Do After This GST Portal Update?

Businesses that earlier faced difficulty filing a GST appeal against NIL demand should review their pending matters.

Taxpayers should:

• Identify orders reflecting NIL or Zero demand;
• Check whether a dispute regarding liability still exists;
• Review available documents and payment records;
• Evaluate the appropriate legal action based on the facts of the case.

If any technical difficulty occurs while filing the appeal, taxpayers may raise a ticket with the GST Helpdesk for assistance.

Businesses should also ensure proper GST registration and compliance management. New businesses can consider GST Registration Services to meet applicable GST registration requirements.

How Ebizfiling Can Help With GST Appeals

GST demand proceedings require careful review of orders, supporting documents, and applicable legal provisions.

Ebizfiling assists businesses with:

• GST notice review;
• Demand order analysis;
• GST compliance support;
• Appeal-related documentation assistance.

Businesses facing a GST appeal against NIL demand situation can seek professional guidance to understand the applicable compliance requirements and filing process. Ebizfiling’s GST support solutions help businesses manage GST-related requirements, including compliance reviews and assistance for GST matters.

Conclusion

The GSTN update allowing a GST appeal against NIL demand orders resolves an important procedural difficulty faced by taxpayers.

Earlier, taxpayers who had already made payment before issuance of a demand order but continued to dispute the liability faced challenges while filing appeals because the GST Portal reflected NIL or Zero demand.

Through GSTN Advisory No. 671, GSTN has removed the previous portal validation and enabled eligible taxpayers to file appeals through Form GST APL-01 against demand orders reflecting NIL or Zero demand amounts.

This update improves access to the GST appellate mechanism while keeping the existing legal framework under Section 107 of the CGST Act and Rule 108 of the CGST Rules unchanged.

Taxpayers should review their individual facts, supporting documents, and applicable legal position before proceeding with an appeal. Proper GST compliance management can help businesses address disputes effectively and maintain regulatory compliance.

Suggested Reads:

GST Section 74 Notice

GST Notice for Sending Money Internationally

All About GST Return Filing in India

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