GSTN Asks Taxpayers To Seek Rectification Where Adjudication Order Reflects NIL Demand Due To Portal Glitch

The Goods and Services Tax Network (GSTN) has advised taxpayers to approach adjudicating authorities for issuance of a rectification order in cases where they are unable to file appeals on the GST portal due to a “NIL” demand reflected in adjudication orders.

In an advisory dated April 3, 2026, GSTN noted that taxpayers are facing difficulties in filing appeals in such cases despite underlying disputes on tax liability.

The issue arises where taxpayers have made payments towards tax, interest, or penalty at the show cause notice (SCN) stage without admitting liability.

Subsequently, adjudicating authorities, in some instances, issue orders treating such payments as full discharge without explicitly determining or recording the actual liability. GSTN explained that when such orders are uploaded, the system generates a Demand ID in the Demand and Collection Register (DCR) with a zero value.

As a result, when taxpayers attempt to file an appeal in Form APL-01 under Section 107 of the Central Goods and Services Tax Act, 2017, the portal restricts filing and may display an error stating that the disputed amount cannot exceed the demand amount.

Clarifying the legal position, GSTN noted that payment made at the SCN stage, without explicit admission, does not amount to acceptance of liability. Taxpayers, therefore, retain the statutory right to challenge such demands.

However, due to the “NIL” demand reflected in the system, taxpayers are unable to exercise this statutory right on the portal.

Taxpayers may use the rectification functionality available on the GST portal to seek correction of the demand amount, following which an appeal may be filed within the prescribed time limits.