The Goods and Services Tax Network (GSTN), through Advisory No. 656 dated 10 April 2026, has introduced a significant procedural update: the pre-deposit percentage field in Form APL-01 is now editable, effective from 6 April 2026.
What Was the Problem?
Under Section 107(6) of the CGST Act, 2017, every appellant filing an appeal before the First Appellate Authority must pre-deposit the full admitted amount plus 10% of the remaining disputed tax (subject to a ceiling of ₹25 crores each under CGST and SGST/UTGST). This pre-deposit is a jurisdictional pre-condition — non-compliance renders the appeal liable to rejection at the threshold itself.
Until 5 April 2026, the GST portal auto-populated this pre-deposit at exactly 10% of the demand and the field was non-editable. This created serious practical difficulties in three common situations:
- When the taxpayer had already paid a portion of the disputed amount through Form GST DRC-03 — the portal did not map that payment to the demand, and demanded full 10% again, effectively requiring double payment.
- When the demand amount was incorrectly reflected on the portal under the wrong head.
- When the admitted and disputed amounts required case-specific calculation different from the portal's automated figure.
What Has Changed?
Effective 6 April 2026, taxpayers and their counsel can now modify the pre-deposit percentage while submitting Form APL-01. The portal allows entry of the actual amount paid, adjusted for any prior payments made through DRC-03 or other permissible modes.
What Remains Unchanged
The GSTN advisory explicitly clarifies that this portal change does not alter the legal obligation under Section 107(6). The Appellate Authority will independently verify the correctness of the pre-deposit amount and the mode of payment during adjudication. An appeal with an under-deposited pre-deposit remains liable to dismissal.
Practitioners must note: the editable field is not a licence to under-deposit. The statutory 10% requirement must be correctly computed and paid — the change only removes the portal's technical rigidity, not the legal requirement.
Practical Guidance for Practitioners
Before filing APL-01, ensure the DRC-03A linkage (as clarified in the GSTN Advisory dated 14 March 2026) is completed wherever applicable. Arrive at the pre-deposit figure through a transparent, case-specific calculation. Retain all payment proof — challans, DRC-03 acknowledgements, and payment receipts — as the Appellate Authority will scrutinise these during adjudication.
Reference: GSTN Advisory No. 656 dated 10 April 2026 | Section 107(6), CGST Act, 2017
This update is for informational purposes. For case-specific advice, consult a qualified tax professional.