In a significant relief to taxpayers, GSTN has introduced a system update allowing editing of the pre-deposit percentage while filing appeals in Form APL-01, effective April 6, 2026. This change aims to resolve practical challenges faced during GST appeal filings.

Legal Background

As per Section 107(6) of the CGST Act, 2017, filing an appeal before the Appellate Authority requires:

• Payment of:

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  • 100% of admitted tax liability, and

  • 10% of the disputed tax amount (subject to prescribed limits)

This pre-deposit is mandatory for admission of appeal.

Issue Faced Earlier

Before this update:

• The GST portal auto-populated a fixed 10% pre-deposit

• Taxpayers could not modify this amount even when:

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  • Pre-deposit was already paid earlier

  • Payment was made under a different head or classification

  • Adjustments were required due to calculation differences

👉 This often resulted in:

• Excess payment

• Incorrect reporting

• Filing difficulties and reconciliation issues

GSTN Update – What Has Changed?

With effect from April 6, 2026, GSTN has enabled:

• Editable pre-deposit percentage field in Form APL-01

• Taxpayers can now:

  • Enter actual amount already paid

  • Adjust percentage as per case-specific facts

  • Avoid duplication of payment

This brings flexibility and aligns the system with practical scenarios.

Important Safeguard

While this feature provides relief, taxpayers must note:

• The Appellate Authority will verify:

  • Correctness of pre-deposit amount

  • Mode of payment

  • Compliance with Section 107(6)

👉 Incorrect or insufficient payment may lead to:

• Rejection of appeal

• Requirement to make additional payment

Practical Implications for Taxpayers

• ✔ Better accuracy in appeal filing

• ✔ Avoidance of excess cash outflow

• ✔ Easier reconciliation of payments

• ⚠ Responsibility shifts to taxpayer to ensure correctness

Key Points to Remember

• Ensure proper documentation of pre-deposit already made

• Cross-check:

  • Electronic Cash Ledger

  • Electronic Credit Ledger

• Maintain clarity on:

  • Disputed vs admitted tax

• Keep working papers ready for scrutiny

Conclusion

The GSTN update allowing editable pre-deposit in Form APL-01 is a welcome move that addresses long-standing practical issues. However, with increased flexibility comes greater responsibility to ensure accurate compliance with legal provisions.

For expert guidance on this topic, contact your tax professional today.