GST Insights India: show cause notice reply, ITC denial, detention, attachment, GSTAT appeals and refunds

237 practice notes across 17 clusters on Goods and Services Tax disputes in India, with the statute, the Supreme Court and High Court decisions, and the steps that follow. Law stated as on 3 September 2026. Published by AMLEGALS; authored by Anandaday Misshra, Founder and Managing Partner.

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Quick answers

What does AMLEGALS GST litigation practice cover?

AMLEGALS handles GST show-cause notice replies under Sections 73, 74 and 74A of the CGST Act 2017, departmental audits, input tax credit disputes, e-way bill seizures, anti-profiteering matters, DGGI summons responses, and representation before adjudicating authorities, GSTAT (GST Appellate Tribunal), High Courts and the Supreme Court of India.

What is the GSTAT and when did it become operational?

The GST Appellate Tribunal (GSTAT) became operational on 24 September 2025 with a Principal Bench in New Delhi and 31 State Benches across 45 locations in India. It provides the first appellate forum dedicated to GST disputes.

What is the GSTAT appeal deadline for older orders?

By notification dated 30 June 2026, the backlog window was extended: appeals against orders communicated before 1 May 2026 had to be filed by 31 July 2026. That window has closed. Orders communicated on or after 1 May 2026 carry the standard three-month limitation under Section 112 of the CGST Act.

What is the pre-deposit requirement for GSTAT appeals?

Filing a GSTAT appeal requires pre-deposit of the full admitted tax plus 10% of the disputed tax, subject to a cap of Rs 20 crore CGST and Rs 20 crore SGST.

What is Section 128A of the CGST Act?

Section 128A provides conditional waiver of interest and penalty for GST demands under Section 73 for financial years 2017-18, 2018-19 and 2019-20, subject to full payment of the tax amount demanded. It was introduced by the Finance (No.2) Act, 2024.

What is Rule 88B of the CGST Rules?

Rule 88B governs the manner of calculating interest on delayed GST payments. It clarifies whether interest runs on gross or net liability and applies from the date tax was due until the date of payment.

Can AMLEGALS help with DGGI investigations and summons?

Yes. AMLEGALS advises businesses on responding to DGGI summons, managing search and seizure proceedings, preparing for statements under Section 70, and defending against subsequent show-cause notices arising from DGGI investigations.

What is the Input Tax Credit (ITC) matching issue under GST?

ITC mismatches arise when GSTR-2B auto-populated credits differ from a taxpayer claim. Common causes include supplier non-filing, GSTIN errors, and timing differences. The Invoice Management System (IMS) introduced from 1 October 2024 allows recipients to accept, reject or keep invoices pending, directly affecting ITC availability.

What is GST 2.0 and when did it take effect?

GST 2.0 is the rate-rationalisation reform approved at the 56th GST Council meeting on 3 September 2025 and effective from 22 September 2025. It consolidated the principal slabs into 5% and 18%, with a 40% rate for specified sin and luxury goods.

Does AMLEGALS handle customs and trade remedy matters?

Yes. The firm advises on customs duty disputes, anti-dumping investigations, safeguard duties, QCO/BIS import compliance, special valuation branch proceedings, provisional release of seized goods, and representation before CESTAT.