The Goods and Services Tax Appellate Tribunal (GSTAT) has introduced an online mechanism through which taxpayers can seek the transfer of appeals involving an identical question of law pending before different benches of the tribunal.
Taxpayers with multiple GST identification numbers (GSTINs) linked to the same permanent account number (PAN) can select appeals involving an identical question of law pending before different benches and file a single transfer application, according to the updated standard operating procedure (SOP) reviewed by Mint.
The GSTAT has identified a substantial number of appeals involving a common legal question across its benches. In an order dated 1 July 2026, the principal bench identified 504 appeals across nine state benches involving the question of whether the tribunal can condone delay beyond the maximum period prescribed under section 107(4) of the Central Goods and Services Tax Act, 2017.
The 504 appeals were spread across Hyderabad, Bhopal, Kolkata, Chennai, Raipur, Guwahati, Ranchi, Vijayawada and Dehradun. Hyderabad accounted for 257 cases, followed by Bhopal with 75 and Kolkata with 46. Chennai had 35 cases, while Raipur, Guwahati, Ranchi, Vijayawada and Dehradun had 22, 21, 17, 16 and 15, respectively.
The principal bench had directed its registry to obtain details of such appeals from the respective state benches and place them before a special bench. The cases provide a concrete example of how the same legal question can result in multiple proceedings before different benches.
The development also assumes significance as the GST taxpayer base has expanded to over 16.8 million as of July 2026, according to government data. However, GSTINs are issued on a state-wise basis, meaning a business operating across multiple states can hold several registrations under the same PAN.
Experts said that the new mechanism could help businesses with operations across several states, where multiple GST registrations under the same PAN can lead to similar tax disputes being litigated before different GSTAT benches.
“The new transfer mechanism is particularly relevant for businesses with operations across several states, which may hold multiple GST registrations under the same PAN. A common tax dispute involving the same legal provision can result in separate appeals before different benches,” said Pankaj Dikshit, executive director and chief AI and data officer, Cygnet.One, a tax technology and financial digital transformation solutions provider.
The SOP provides a procedural route for such appeals to be brought together rather than requiring taxpayers to pursue separate transfer requests for each matter, he said.
The mechanism could help reduce the possibility of divergent rulings on an identical question of law being decided by different GSTAT benches. “The mechanism provides a structured way to deal with the same question of law arising in multiple appeals before different GSTAT benches. This can help reduce fragmented litigation and the possibility of divergent views on the same legal issue, while ensuring that transfer requests are examined through a defined process,” said Vijay Kumar, partner, Fox Mandal, a law firm.
The statutory basis for the transfer mechanism is Section 109(6) of the CGST Act, under which the president of GSTAT can distribute the tribunal’s business among benches and transfer cases from one bench to another, subject to the applicable jurisdictional provisions.
The tribunal has also introduced a separate SOP for online filing of replies by respondents, indicating a broader move towards digitizing procedural steps in GST appellate proceedings.
Mint‘s queries emailed to the Union finance ministry remained unanswered.
The development comes as GST has become an increasingly important revenue source for the government, with gross collections rising 14.7% year-on-year to ₹2.04 trillion in September from ₹1.77 trillion a year ago.
September was the third month this fiscal year in which GST collections crossed the ₹2 trillion mark, but were below the ₹2.11 trillion collected in July, when the monthly mop-up crossed ₹2 trillion for the second time. July’s collection was the second-highest since GST was introduced in July 2017, after the record ₹2.43 trillion collected in April 2026.
