The GSTN has issued an Advisory dated 07.09.2026, has enabled taxpayers to file appeals in Form GST APL-01 against demand orders showing “NIL” or “Zero” demand, where a dispute regarding tax liability continues to exist but the taxpayer had already paid the disputed amount before issuance of the demand order. 

The portal change addresses a procedural anomaly wherein payment of the disputed liability before issuance of the order resulted in a NIL/Zero demand, which in turn prevented the taxpayer from filing an appeal electronically. By removing this validation, GSTN has recognised that the existence of an appealable dispute cannot be determined merely by the quantum of demand remaining outstanding in the order. Thus, even where the monetary demand is NIL or Zero due to prior payment, the taxpayer can now challenge the underlying determination of liability before the appellate authority.

Accordingly, taxpayers can now file an appeal in Form GST APL-01 against such demand orders despite the demand being reflected as NIL/Zero on the GST Portal.

Key takeaway:

The procedural restriction on filing appeals merely because the demand order reflects NIL/Zero demand has been removed. Taxpayers having a substantive dispute regarding liability can now pursue the statutory appellate remedy through the GST Portal.

In case of any technical difficulty while filing the appeal, taxpayers may raise a ticket with the GST Helpdesk.

The Complete Advisory can be accessed at https://www.gst.gov.in/newsandupdates/read/671