Identify the forum before selecting the summary
CGST Rule 113(1) requires the Appellate Authority to issue a summary in FORM GST APL-04 along with its section 107(11) order. Current sub-rule (2) instead requires the Appellate Tribunal to issue, or cause to be issued, a summary in FORM GST APL-04A with its section 113(1) order. This guide, checked on 28 October 2026, addresses that distinction and the final-demand bridge, rather than grounds for admission of additional evidence. CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115.
Do not reuse the pre-amendment Tribunal wording
Notification 13/2025–Central Tax dated 17 September 2025 substituted Rule 113(2) with effect from 22 September 2025. The older wording referred to the jurisdictional officer and APL-04 for the Tribunal result. The current rule's APL-04A and issuing responsibility must be checked against the actual forum. Rule 115 separately retains APL-04 for the specified Court-confirmed demand statement; it does not turn the Tribunal summary back into that form. CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115.
Read the operative order and summary together
The summary must clearly indicate the final demand confirmed. Preserve the signed or authenticated substantive order, its communication evidence and the related summary. Separate the original demand from the amount confirmed after appeal, and distinguish tax heads, interest, penalty and other amounts actually determined. A spreadsheet containing only the reduction cannot substitute for the confirmed-demand figure. No unverified field label or portal screen sequence is prescribed here. CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115.
Payments are a separate reconciliation layer
A confirmed demand is not automatically the unpaid balance. Match valid pre-deposits and other payments to the correct proceeding, liability and appropriation evidence. Conversely, do not reduce the order's confirmed amount merely because cash was paid earlier. The illustrations isolate these arithmetic layers; they do not assume that every payment can be appropriated without further legal and portal action or that every favourable order creates an automatic refund. CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115.
Investigate inconsistent figures without inventing a remedy
If the summary and operative order differ, preserve both versions and communicate the exact component mismatch through the appropriate supported channel. Determine whether correction of the summary, rectification of the order, further appeal or another legally available step is actually needed. A clerical request is not assumed to extend a statutory appeal deadline. This article does not promise automatic portal correction, demand deletion or recovery protection from merely raising a query. CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115.
Use an order-by-order control schedule
Track forum, order number, relevant period, tax head, original demand, confirmed demand, valid payments and unresolved differences. Section 84 and the recovery rules may require separate implementation analysis; this article supplies the Rule 113 order-to-summary control rather than replacing those procedures. Treat a proposed future challenge separately from the existing operative outcome and obtain the actual stay or other legal basis before changing recovery assumptions. CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115.
Applicable primary references
CGST Rules: Rule 113(1)–(2), September 2025 substitution and Rule 115
GST Council September 2025 newsletter: Notification 13/2025–Central Tax and Tribunal APL-04A
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Confirmed amount versus relief
Assume original CGST ₹5,00,000 and SGST ₹5,00,000 are reduced by the order to ₹3,00,000 each. Final confirmed tax is ₹6,00,000; relief is ₹4,00,000. The relief figure is not the final demand figure.
Illustrative example 2: Keep components visible
An order confirms tax ₹6,00,000, quantified interest ₹60,000 and penalty ₹60,000. Their total is ₹7,20,000. Reporting only tax would omit ₹1,20,000; these amounts are assumptions, not a statutory interest or penalty rate calculation.
Illustrative example 3: Payment does not rewrite the order
Assume confirmed demand ₹8,00,000 and ₹3,00,000 of valid, correctly appropriated payments. The model unpaid balance is ₹5,00,000, while confirmed demand remains ₹8,00,000. Further payment or refund treatment depends on the actual record.
Illustrative example 4: Successive forums
An Appellate Authority confirms ₹8,00,000 and a later Tribunal order confirms ₹5,00,000 on the same model scope. The additional reduction is ₹3,00,000. Retain the Authority's APL-04 and the Tribunal's current APL-04A against their respective orders.
Illustrative example 5: A component mismatch
The operative order confirms CGST ₹3,50,000 but its summary shows ₹4,50,000. The component difference is ₹1,00,000. Record the evidence and pursue the appropriate correction; the model does not declare either an automatic new demand or an automatic stay.
Illustrative example 6: Do not add old and new outcomes
An original model demand ₹12,00,000 is modified to ₹9,00,000. The same liability is not ₹21,00,000 by adding both stages. The reduction is ₹3,00,000; confirm scope and implementation before updating the liability ledger.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the forum | Authority, Tribunal or Court |
| 2 | Read the applicable rule version | Rule 113 substitution and actual order date |
| 3 | Obtain the operative order | Authenticated copy and communication evidence |
| 4 | Identify the correct summary | APL-04 or APL-04A on the actual forum facts |
| 5 | Match the proceeding | GSTIN, period, original order and appeal reference |
| 6 | Reconcile each tax head | Confirmed figures against the operative order |
| 7 | Reconcile other components | Actual interest, penalty and other determinations |
| 8 | Match valid payments | Liability mapping and appropriation evidence |
| 9 | Resolve discrepancies | Specific written mismatch and available legal route |
| 10 | Retain the final control file | Order, summary, payment bridge and unresolved deadlines |
Sixteen practitioner FAQs
1. Which rule governs the first appellate summary?
Rule 113(1), read with section 107(11).
2. Which form does that sub-rule specify?
FORM GST APL-04.
3. Which form does current Rule 113(2) specify for the Tribunal?
FORM GST APL-04A.
4. Who issues or causes the Tribunal summary to be issued?
The Appellate Tribunal under the current wording.
5. When did the identified substitution take effect?
22 September 2025 under Notification 13/2025–Central Tax.
6. Can older Tribunal wording be copied without checking?
No. It referred to a different form and issuing responsibility.
7. Does Rule 115 eliminate the APL-04A distinction?
No. It separately deals with demand confirmed by the specified Courts.
8. Is the summary itself a fresh appeal application?
No. It summarises the corresponding order's confirmed demand.
9. Is relief the same as confirmed demand?
No. Relief is the reduction from the earlier amount on matched scope.
10. Should prior payments reduce the figure stated as confirmed demand?
Keep the order's confirmed amount distinct from the separately reconciled unpaid balance.
11. Can every pre-deposit be assumed automatically appropriated?
No. Verify actual mapping and legal treatment.
12. Does a favourable result guarantee an automatic refund?
No. Establish the applicable entitlement and process.
13. What should a mismatch report identify?
The order, summary, component, stated amounts and precise difference.
14. Does a correction query extend appeal limitation by itself?
No such extension is assumed.
15. Can successive order amounts simply be added?
No. Reconcile whether the later order modifies the same liability.
16. What proves implementation is complete?
A matched operative outcome, correct summary and supported liability/payment record.
Conclusion
Match the appellate forum to its current summary form, then reconcile confirmed demand, components and payment evidence without treating the summary as a new appeal.
Sources and primary references
GST Council September 2025 newsletter: Notification 13/2025–Central Tax and Tribunal APL-04A