🔑 In one line

If you paid a disputed GST demand before the order was issued — leaving the order showing "NIL" — you couldn't appeal it until now. GSTN just fixed that.

Advisory 671
Dated 7 Sept 2026
GST APL-01
Form to use
3 months
Filing window (Sec. 107)

The problem this fixes

Picture this: you get a Show Cause Notice, and — without admitting you actually owe the tax — you pay the disputed amount to avoid it snowballing with interest. Later, the adjudicating authority issues the formal demand order, and because you'd already paid, it reflects a "NIL" or "Zero" demand.

Sounds fine — except you still disagree with the underlying finding that you owed the tax at all. Until this week, the GST Portal's own validation blocked you from filing an appeal in Form GST APL-01, throwing an error that the disputed amount couldn't exceed the demand amount — which was zero. Genuinely aggrieved taxpayers were stuck with no route to challenge the finding.

✅
What changed
The validation has been removed
Via Advisory No. 671 dated 7 September 2026, GSTN has removed the portal restriction. Taxpayers can now file Form GST APL-01 directly against a NIL/Zero demand order, even though no monetary amount is shown as outstanding.
⏱️
Background
This isn't the first attempted fix
An earlier advisory (3 April 2026) had tried to solve this by requiring a rectification order before an appeal could be filed — an extra procedural step that added delay. This week's advisory removes that hurdle entirely and allows direct filing.

Common confusions — cleared up

❌ Confusion

A NIL demand order means there's nothing left to dispute.

✅ Actual rule

The demand amount and the underlying liability finding are separate — you can still contest the finding even at zero rupees outstanding.

❌ Confusion

I need a rectification order first before I can appeal.

✅ Actual rule

That extra step has been removed — you can file Form GST APL-01 directly now.

If this applies to you

✅ What to do
1
Check your filing window — Section 107 gives 3 months from the order date, plus a condonable 1-month extension.
2
File Form GST APL-01 directly on the portal — no rectification order needed first.
3
Raise a helpdesk ticket if you hit any technical issue during filing.
4
Bring in a CA if the underlying dispute involves a significant liability finding, even at zero net demand.

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