The provisional receipt is not the whole filing record
CGST Rule 108 distinguishes an order already uploaded on the portal from an order not uploaded there. For the latter, a self-certified copy submitted within seven days preserves the provisional-acknowledgement date; submission outside that period makes the copy-submission date the filing date under the rule. Its Explanation treats the appeal as filed only when final acknowledgement with an appeal number is issued. This guide was checked on 28 October 2026 and addresses first appeals, not GSTAT forms. CGST Rule 108(1)–(3), provisos and Explanation.
Establish whether the appealed order was uploaded
Rule 108(1) uses FORM GST APL-01 with relevant documents and an immediate provisional acknowledgement. Sub-rule (3) provides final acknowledgement in FORM GST APL-02. Preserve the appealed order's actual upload status and the acknowledgement timestamps. A screenshot showing an order number is not automatically evidence that the decision itself was available. The current rule differs from the older blanket certified-copy wording substituted in December 2022. CGST Rule 108(1)–(3), provisos and Explanation.
Use the correct copy requirement
Where the order is not uploaded, the first proviso requires a self-certified copy within seven days from filing APL-01. Do not insist that the current wording universally requires a separately obtained authority-certified paper copy, and do not assume an unsigned internal draft is sufficient self-certification. Retain the actual submitted document, certification and receipt evidence. The second proviso assigns the copy-submission date if the copy was not submitted within that period. CGST Rule 108(1)–(3), provisos and Explanation.
Keep filing date and acknowledgement completion distinct
A later final acknowledgement does not automatically replace the date the rule assigns where its conditions are met. Conversely, merely having a provisional acknowledgement does not satisfy the Explanation's final-acknowledgement condition. Follow up missing final records and defects using the actual proceeding's evidence. The numerical examples assume the stated documents are valid and final acknowledgement is ultimately issued; they do not guarantee admission. CGST Rule 108(1)–(3), provisos and Explanation.
Manual filing is conditional
The proviso to Rule 108(1) permits manual APL-01 filing only where the Commissioner has notified it or electronic filing cannot occur because the appealed decision or order is unavailable on the common portal. Preserve the factual or notified basis rather than treating manual filing as a free alternative in every case. A generic portal difficulty is not automatically the particular condition stated in the rule. CGST Rule 108(1)–(3), provisos and Explanation.
Do not turn the copy window into an appeal extension
Check section 107 limitation, communication of the order and any legally available condonation independently. The seven-day copy rule is not seven extra days added to every appeal deadline. The examples use express elapsed-day assumptions, no holiday adjustment and no conclusion about the last permissible appeal day. Record the assigned date before applying the actual limitation framework, including the effect of any late copy. CGST Rule 108(1)–(3), provisos and Explanation.
Applicable primary references
CGST Rule 108(1)–(3), provisos and Explanation
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Uploaded order
Assume APL-01 and provisional acknowledgement on 1 October 2026, an already-uploaded order and final APL-02 on 5 October. The assigned filing date under Rule 108(3) remains 1 October on these facts; the final acknowledgement arrives four elapsed days later.
Illustrative example 2: Copy well within seven days
Assume the order is not uploaded, APL-01 and provisional acknowledgement on 1 October, valid self-certified copy submitted on 6 October and final acknowledgement later. Five elapsed days separate filing and copy submission. The model preserves 1 October as the assigned date.
Illustrative example 3: Copy outside the window
On the same 1 October APL-01 facts, assume the copy is submitted on 10 October, nine elapsed days later. This is outside seven days under the stated no-adjustment model. The copy-submission date, 10 October, becomes the filing date under the second proviso.
Illustrative example 4: Different month, same control
Assume APL-01 on 20 October 2026 and copy submission on 25 October. The elapsed interval is five days. With the other first-proviso conditions satisfied, preserve the provisional-acknowledgement date rather than the later copy date.
Illustrative example 5: Measure the assigned-date shift
Assume APL-01 on 20 October and copy on 30 October, ten elapsed days later. The second-proviso model assigns 30 October, shifting the relevant date by ten days. Whether that is within limitation must be separately tested; the example does not grant condonation.
Illustrative example 6: Do not substitute final processing delay
Assume APL-01 and provisional acknowledgement on 1 October, a valid within-window copy on 6 October and final acknowledgement on 15 October. The final record arrives fourteen days after the provisional acknowledgement, but the assigned filing date is still 1 October on these facts, not 15 October.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the appeal route | Section 107 first appeal, not Tribunal appeal |
| 2 | Obtain the appealed order | Complete authenticated decision and communication evidence |
| 3 | Establish upload status | Portal record of the actual decision |
| 4 | Preserve APL-01 evidence | Submitted form, documents and timestamp |
| 5 | Preserve provisional acknowledgement | Actual issue date and reference |
| 6 | Identify the copy condition | Uploaded-order case or self-certified-copy case |
| 7 | Verify valid copy submission | Certification, receipt and actual date |
| 8 | Assign the filing date | Rule 108(3) and its two provisos |
| 9 | Obtain final APL-02 | Appeal number and any defect-resolution evidence |
| 10 | Test limitation independently | Communication date, actual assigned date and lawful condonation route |
Sixteen practitioner FAQs
1. Which appeal does Rule 108 address?
Appeal to the Appellate Authority under section 107(1).
2. Which application form is specified?
FORM GST APL-01.
3. Which final acknowledgement form is specified?
FORM GST APL-02.
4. Is provisional acknowledgement the complete filing record?
No. Read the final-acknowledgement Explanation as well.
5. What determines the first copy branch?
Whether the appealed order is uploaded on the common portal.
6. What copy does the current first proviso specify?
A self-certified copy of the decision or order.
7. Does the rule universally retain the older certified-copy wording?
No. The current substituted wording makes the stated distinctions.
8. What is the specified copy period for a non-uploaded order?
Seven days from filing APL-01.
9. What date is preserved with a valid within-period copy?
The date of issue of provisional acknowledgement on the stated conditions.
10. What happens if the copy is outside that period?
The second proviso uses the copy-submission date as the filing date.
11. Does later final acknowledgement always change the assigned date?
No. Apply the relevant branch of sub-rule (3).
12. Can a missing final acknowledgement simply be ignored?
No. The Explanation expressly requires it for treating the appeal as filed.
13. Is manual filing freely available in all cases?
No. The proviso to sub-rule (1) specifies its conditions.
14. Are seven additional appeal-limitation days automatically granted?
No. Limitation must be independently checked.
15. Do the illustrations determine holiday extensions?
No. They expressly use elapsed-day models without holiday adjustment.
16. What should the final file preserve?
Order status, form and acknowledgement records, valid copy receipt and limitation working.
Conclusion
Separate provisional acknowledgement, the seven-day order-copy test and final APL-02 acknowledgement before assessing a first appeal’s filing date.