CBIC Issues Procedural Guidelines for Review and Appeals in Multi-State GST Cases

The Central Board of Indirect Taxes and Customs (CBIC) has issued procedural guidelines to clarify the review and appeal process for adjudication orders in multi-state Goods and Services Tax (GST) cases handled by Common Adjudicating Authorities (CAAs). This move addresses jurisdictional ambiguities and aims to streamline post-adjudication processes involving high-value investigations by the Directorate General of GST Intelligence (DGGI).

The clarification, issued through Circular No. 250/07/2025-GST dated June 24, 2025, addresses a critical gap in the GST post-adjudication process—one that had led to delays, jurisdictional confusion, and procedural lapses in high-value investigations involving tax evasion.

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New framework to ease procedural delays in multi-jurisdictional GST disputes

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To remedy procedural delays and legal uncertainty in high-value investigations, CBIC has clarified that the Principal Commissioner or Commissioner of Central Tax, under whom the CAA functions, will act as the reviewing authority under Section 107 of the Central Goods and Services Tax (CGST) Act. The same official will also exercise revisional powers under Section 108, both of which pertain to handling appeals against demand or adjudication orders.

Furthermore, appeals against orders passed by CAAs will be handled by the Commissioner (Appeals), who has territorial jurisdiction over the Principal Commissioner or Commissioner of Central Tax supervising the adjudicating authority.

Clarifying appellate authority for CAA orders

Prior to this notification, there was no formal framework specifying who could review or hear appeals against decisions made by CAAs—officials designated under Notification No. 02/2017 to handle cases issued by the DGGI. Although CBIC’s Circular No. 239/33/2024-GST defined the territorial jurisdiction of CAAs, it left post-adjudication processes unaddressed.

As per media reports, to close this procedural loophole, the CBIC sought legal consultation from the Union Ministry of Law and Justice. This resulted in the issuance of a clear and structured clarification on June 23, 2025.

Key provisions clarified include:

1. Reviewing authority (Section 107): The Principal Commissioner or Commissioner of Central Tax under whose jurisdiction the CAA functions will be responsible for reviewing the adjudication order.
2. Revisional authority (Section 108): The same officer will also serve as the revisional authority.
3. Appellate authority: Appeals against CAA orders will be handled by the Commissioner (Appeals), who has territorial jurisdiction over the Commissionerate specified in the 2017 notification.
4. Departmental representation: The Principal Commissioner or Commissioner supervising the CAA will represent the department in appeals and may appoint subordinate officers for this purpose.

Clarification expected to streamline appellate procedures in complex cases

To reinforce the GST enforcement ecosystem, the recent clarification from CBIC provides a structured approach for handling review and appeal processes in cases initiated by the DGGI. These cases often involve intricate investigations into major tax evasion, fraudulent input tax credit (ITC) claims, and fake invoice networks—areas that demand prompt adjudication and a clear appellate pathway.

By clearly defining roles and responsibilities within the existing tax framework, the clarification aims to:

• Resolve procedural bottlenecks arising from jurisdictional overlaps.
• Enhance administrative accountability by linking appellate functions to specific tax jurisdictions.
• Facilitate prompt departmental appeals, which were often delayed due to unclear mandates.
• Encourage uniformity in legal interpretation and enforcement across different regions.

Tax professionals have broadly endorsed the move, noting that it will improve compliance and reduce litigation burdens for businesses involved in wide-ranging GST investigations. Sectors frequently under scrutiny—such as banking, insurance, online gaming, hospitality, real estate, FMCG, manufacturing, and logistics—are likely to benefit from greater procedural certainty.

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