VR1 AssociatesCustoms, GST, SEZ and DGFT
Tool

Appeal and pre-deposit planner

The forum, the last date, and the money that has to be deposited before the appeal is admitted, with the statutory percentage, the ceiling and the arithmetic shown line by line.

What this appeal will require

Rule set 2026.08
The part you are contesting, not the admitted part.
Where only a penalty is in dispute, the percentage runs on the penalty.

The two regimes treat the second appeal differently

Under the GST law the ten per cent at the Tribunal is in addition to the ten per cent already paid at the first appeal. Under the Customs Act the requirement at the Tribunal is ten per cent in total, and what was deposited earlier counts towards it. The planner applies each correctly.

  • GST: Section 107(6) and 112(8), CGST Act 2017
  • Customs: Section 129E, Customs Act 1962

The condonation window is not a second deadline

Under the GST law the Appellate Authority can allow one further month and no more. Under the Customs Act the Commissioner (Appeals) can allow thirty further days and no more. Past that, the authority has no power to admit the appeal at all, however good the matter is.

  • Section 107(4), CGST Act 2017
  • Proviso to Section 128(1), Customs Act 1962
Reading the number

What the pre-deposit does, and what it does not do.

It buys the stay

Once the deposit is made and the appeal is filed, recovery of the balance stays suspended while the appeal is pending. That is the practical reason the figure matters more than the merits in the first fortnight.

It is computed on the disputed amount

Not on the whole demand. The admitted part is paid in full separately, and the percentage runs on what you are actually contesting.

It is refundable with interest if you succeed

The deposit is not a payment of the demand. Where the appeal succeeds it comes back, and the statute provides for interest on it.

It does not decide whether to appeal

A large pre-deposit on a strong matter is worth funding. A small one on a weak matter still buys you years of cost. The number is an input to the decision, not the decision.

Work the deposit out before the fortnight is gone.

The appeal window is short, the money has to be arranged, and the grounds take longer to write well than most people expect.