GST Portal Update: Pre-Deposit Field in APL-01 Now Made Editable

MOHAN & CHANDRASEKHAR

Chartered Accountants

Hosur  |  Bengaluru  |  Chennai

GSTN ADVISORYGST Portal Update: Pre-Deposit Field in APL-01 Now Made Editable

GSTN Advisory dated 10th April 2026  —  Critical Relief for Appellants

April 2026

1.  Background

Under Section 107(6) of the CGST Act, 2017, every appellant filing an appeal before the First Appellate Authority is required to pre-deposit:

  • The full admitted amount of tax, interest, fine, fee and penalty arising from the impugned order; and
  • 10% of the remaining disputed tax (subject to a maximum of ₹25 crores each under CGST and SGST/UTGST).

This pre-deposit is a jurisdictional pre-condition for admission of the appeal — non-compliance renders the appeal liable to rejection at the threshold itself.

2.  The Problem — Portal Rigidity Causing Hardship

Until recently, when an appellant filed Form GST APL-01 on the GST portal, the pre-deposit percentage was auto-populated as 10% and was non-editable. This one-size-fits-all approach created practical difficulties in the following situations:

  • Where the pre-deposit had already been made through Form GST DRC-03 or through other means, and the linkage via DRC-03A was not yet reflected;
  • Where the demand amount was incorrectly reflected under the appropriate head in the Electronic Liability Register;
  • Where the admitted amount itself was in dispute and the system-computed 10% did not align with the appellant’s calculation; and
  • Where partial payments made during investigation were to be adjusted against the pre-deposit obligation.

In all these scenarios, the rigidity of the non-editable field forced appellants into either making excess payments or being unable to file the appeal altogether — causing serious procedural prejudice.

3.  The GSTN Solution — Editable Pre-Deposit Field (w.e.f. 06.04.2026)

GSTN, through its Advisory dated 10th April 2026, has announced that effective from 6th April 2026, the pre-deposit field in Form GST APL-01 has been made editable. This enables appellants to:

  • Modify the pre-deposit percentage as applicable to their specific case, instead of being locked into the system-generated 10%;
  • Calculate and pay the correct amount on the basis of the actual admitted and disputed amounts as computed by the appellant; and
  • Proceed with filing the appeal without being blocked by a portal-generated mismatch.

The GSTN has clarified that the Appellate Authority will subsequently verify the correctness of the pre-deposit amount and the mode of payment during the course of adjudication of the appeal.

4.  Practical Implications — Scenario-Wise Impact

ScenarioPosition Before 06.04.2026Position After 06.04.2026
DRC-03 payment already made during investigationForced to pay 10% pre-deposit againEnter modified % reflecting actual balance payable
Demand incorrectly reflected in the portalCould not override system-generated figureEditable field allows correction
Appellant disputes the admitted amountSystem-computed figure was binding on the appellantAppellant can input correct computation
Partial payments made during investigation stageNot adjustable at the time of filing appealCan now be factored in while entering pre-deposit %

5.  A Word of Caution

The editability of the pre-deposit field is a procedural relief — it does not dilute the substantive obligation under Section 107(6). The Appellate Authority retains full power to examine whether the pre-deposit made is correct in law and in quantum. Appellants must therefore:

  • Maintain clear documentation of all prior payments (DRC-03, challan, bank evidence) that are being set off against the pre-deposit;
  • Ensure that the DRC-03A linkage (as clarified in the earlier GSTN Advisory dated 14.03.2026) is completed before filing, wherever applicable;
  • Arrive at the pre-deposit figure through a transparent, defensible calculation — as the Appellate Authority will scrutinise this during adjudication; and
  • Not treat the editable field as a licence to under-deposit — deliberate under-payment of pre-deposit remains a ground for dismissal of appeal.

6.  Our Observation

This update, read together with the earlier advisory on DRC-03A linkage (March 2026), represents a significant step towards aligning the GST portal’s functionality with real-world litigation realities. For years, the rigidity of the pre-deposit mechanism on the portal has been a source of genuine hardship — particularly for taxpayers caught between investigation-stage voluntary payments and the appeal-stage portal validations.

The move to make the field editable, with post-facto verification by the Appellate Authority, reflects a mature and trust-based approach to compliance — one that balances taxpayer convenience with departmental oversight.

Taxpayers with pending APL-01 filings are strongly advised to take immediate advantage of this facility.

For assistance in computing pre-deposit, filing APL-01, or strategising GST appeals, please reach out to our offices.

Mohan & Chandrasekhar, Chartered Accountants  |  Hosur  |  Bengaluru  |  Chennai

This circular is for general information purposes only and does not constitute legal or professional advice specific to your facts.