Difficulty in filing appeals on the GST portal in cases where adjudication orders reflect “NIL” demand due to prior voluntary payment
GST
Dated:- 3-4-2026
Subject: reg.
1. Introduction
• It has come to the notice of GSTN that certain taxpayers are facing difficulties in filing appeals on the GST portal against demand orders wherein the demand amount is reflected as “NIL,” despite the existence of a dispute regarding tax liability.
• This situation generally arises in cases where the taxpayer has made payment of tax, interest, or penalty (fully or partially) at the stage of issuance of the Show Cause Notice (SCN), without admitting the liability, and the adjudicating authority has subsequently issue
= = = = = = = =
Plain text (Extract) only
For full text:-Visit the Source
= = = = = = = =
ount cannot be more than demand amount itself.”
• Since no liability is reported by the tax officer on the GST portal, the system blocks the taxpayer from filing an appeal.
3. Nature of Issue:
It is clarified that:
• Payment made during the SCN stage, without explicit admission of liability, does not amount to acceptance of the demand.
• In such cases, the taxpayer retains the right to contest the liability and file an appeal under Section 107 of the Central Goods and Services Tax Act, 2017.
However, where the adjudication order incorrectly reflects a “NIL” demand, the taxpayer is unable to exercise this statutory right due to the NIL demand reflected in the system.
4. Alternate solution:
= = = = = = = =
Plain text (Extract) only
For full text:-Visit the Source
= = = = = = = =