In an important procedural facilitation for taxpayers and departmental respondents appearing before the Goods and Services Tax Appellate Tribunal (GSTAT), a Standard Operating Procedure (SOP) for online filing of Reply by a Respondent has been made available on the GSTAT filing portal on September 29, 2026. The facility is intended for respondents who wish to submit their reply to an appeal without filing cross-objections in Form GST APL-06. The SOP specifically states that it lays down the procedure for respondents to file a reply, where required, to an appeal filed against them. GSTAT – File-Reply-SOP
The facility draws its statutory basis from Rule 36 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025, notified by the Ministry of Finance, Department of Revenue vide Notification No. G.S.R. 256(E), dated April 24, 2025, issued in exercise of powers under Section 111 of the Central Goods and Services Tax Act, 2017.
Under Rule 36(1), each respondent may file a reply to the petition or application, together with copies of relevant documents, either personally or through an authorised representative, with the Registrar in the manner specified by the Tribunal within one month of receipt thereof. The Rule also requires a copy of such reply and supporting documents to be served forthwith upon the applicant. Rule 36(2) further provides that, upon receiving such reply or documents, the applicant is required to specifically admit, deny or rebut the facts stated by the respondent and may state such additional facts as considered necessary.
This mechanism is distinct from the statutory facility of filing cross-objections. Rule 35 of the GSTAT (Procedure) Rules, 2025 separately deals with registration and numbering of prescribed forms of cross-objections, applications and other proceedings. Accordingly, the new portal workflow enables a respondent who merely wishes to contest or respond to the grounds taken in the appeal to file a Reply, without necessarily invoking the cross-objection mechanism.
As per the SOP, the respondent is required to log in to the GSTAT Portal and navigate to “Respondent Corner → File Reply”. The respondent can thereafter select “Search by Case No.” and enter relevant particulars including Security Code, Case Type, Case Number, Location and Case Year. GSTAT – File-Reply-SOP
After the required case particulars are entered, the concerned appeal is displayed on the portal and the respondent may proceed through the “Click to Upload” option. A separate window then opens for uploading the Reply and supporting documentation. GSTAT – File-Reply-SOP
The SOP further provides that the respondent will select his or her name from the dropdown menu, following which the remaining details are auto-populated. The user must thereafter select the appropriate e-sign utility and choose “Reply” as the Document Type. The portal displays the mandatory requirements applicable to the document before allowing the file to be uploaded. GSTAT – File-Reply-SOP
Upon successful upload, the document appears in the “Submit Document List” along with relevant particulars such as Party Name and Document Type. The portal also provides facilities to view or delete the uploaded document before final submission. The Reply is finally filed by clicking on the “Submit” button. GSTAT – File-Reply-SOP
After submission, the GSTAT Portal generates a confirmation that the document has been successfully submitted and also provides an option to Print Receipt, thereby creating an electronic acknowledgement of the filing. GSTAT – File-Reply-SOP
Significance for GSTAT Proceedings
The availability of this dedicated Reply-filing functionality provides procedural clarity to respondents who do not intend to file cross-objections but nevertheless wish to place their defence, factual submissions and supporting documents on record. It operationalises the separate procedure contemplated under Rule 36 of the GSTAT (Procedure) Rules, 2025 and facilitates electronic filing directly through the Respondent Corner of the GSTAT Portal.
The development is particularly relevant because a Reply under Rule 36 and a cross-objection are procedurally distinct remedies. Respondents should therefore evaluate whether they merely wish to answer the appellant’s grounds through a Reply or whether they independently seek relief through a cross-objection under the applicable GST provisions and rules.
The Complete SOP can be accessed at: https://efiling.gstat.gov.in/downloads/manual/File-Reply-SOP.pdf
