The CBIC had issued Circular No. 250/07/2025-GST dated 24.06.2025, addressing the review, revision, and appeal mechanism for Orders-in-Original (OIOs) passed by Common Adjudicating Authorities (CAA) for Show Cause Notices (SCNs) issued by the DGGI.
According to the new guidelines, the authorities responsible for reviewing and hearing appeals against such orders will be those under whose administrative control the CAAs (Joint or Additional Commissioners) are posted.
| Function | Responsible Authority |
| Review under Section 107 | The Principal Commissioner or Commissioner of Central Tax under whose jurisdiction the CAA (Additional/ Joint Commissioner is posted. |
| Revisional Power under Section 108 | The same jurisdictional Principal Commissioner/Commissioner shall act as Revisional Authority. |
| Appeal Procedure under Section 107 | Commissioner (Appeals) corresponding to the territorial jurisdiction of the Principal Commissioner or the Commissioner of Central Tax, under whom the said Common Adjudicating Authority (Additional/ Joint Commissioner) is posted, as specified in Table III of notification No. 02/2017-Central tax dated 19th June, 2017. |
| Department’s Representation in Appeals | Principal/Commissioner of Commissionerate where CAA is posted will represent the department in any appeal, and may designate a subordinate officer for filing and pursuing appeals. |
| DGGI involvement | Reviewing/revisional authority may seek comments from the issuing DGGI formation before deciding on the OIO passed by the CAA. |
Background and Need for Clarification
With the issuance of Notification No. 02/2017-Central Tax dated 19.06.2017, and Circular No. 239/33/2024-GST dated 04.12.2024, certain Additional/Joint Commissioners posted in specific GST Commissionerates have been designated as Common Adjudicating Authorities (CAAs) for adjudicating SCNs issued by DGGI. While these notifications covered the assignment and territorial jurisdiction of CAAs, they were silent on the procedural framework for Review of their orders under Section 107(2), Revision under Section 108, and Appeal under Section 107(1).
This ambiguity created procedural complications regarding who would review, revise, or hear appeals against such orders—whether it would be DGGI or the jurisdictional officers under whom the CAA is posted.
The Complete Circular can be accessed at https://taxo.online/wp-content/uploads/2025/06/Circular-No-250-2025.pdf
