The structural complexity of the Goods and Services Tax (GST) landscape requires a highly tactical approach to dispute resolution. With the enforcement of strict data analytics by the GST department and the roll-out of the automated scrutiny modules, businesses face aggressive tax demands and unexpected input tax credit (ITC) reversals.
At AXIAFIN, our specialized indirect tax litigation division provides end-to-end representation. Backed by our Retained Senior Counsel who hold 20 years of expertise in indirect tax litigations, we handle disputes seamlessly across all tiers — from initial Show Cause Notices (SCN) and Audits to the First Appellate Authority and the newly operational GST Appellate Tribunal (GSTAT).
The department initiates proceedings through system-based audits, return scrutinies, or anti-evasion investigations. If discrepancies are found, they issue a Show Cause Notice. The final outcome relies entirely on your written submissions and structural defenses filed on the GST portal.
If an adjudication order (Order-in-Original) is prejudicial to your business, a statutory appeal must be filed in Form GST APL-01 within three months. To admit this appeal, a mandatory pre-deposit of 10% of the disputed tax amount must be paid. Notably, the First Appellate Authority cannot remand the case back to the original officer; they must pass a final order confirming, modifying, or annulling the demand.
As the ultimate fact-finding authority under the GST law, GSTAT is now fully operational with active online e-filing. Appeals against the First Appellate Order are filed in Form GST APL-05. Critical Compliance Note: For all backlog dispute orders issued since 2017 and communicated before April 1, 2026, the Ministry of Finance has set a strict, final deadline of June 30, 2026 to file appeals before GSTAT. Missing this window permanently bars the assessee from accessing the tribunal.
We dismantle departmental allegations by reconstructing the transaction trail. Our team handles the heavy lifting of matching invoices, checking supplier e-way bills, securing ledger confirmations, and building an airtight paper book of evidence to justify every single rupee of ITC claimed.
Our legal experts draft your replies and appeals with meticulous detail. We focus heavily on spotting procedural lapses by the department — such as notices issued without a valid Document Identification Number (DIN), vague allegations lacking specific grounds, or demands raised beyond the statutory limitation periods.
We provide clear financial planning regarding the mandatory pre-deposits (10% at the First Appeal stage and an additional 10% at the GSTAT stage), ensuring your appeals are admitted smoothly without unnecessary cash flow blockages.
With the GSTAT portal live, our team manages your digital filings seamlessly. Our Retained Senior Counsel — veterans with 20 years of experience delivering outperforming results in indirect tax courtrooms — personally argue your matters before the Tribunal benches to secure stays on recovery and win final reliefs.
Massive demands raised due to mismatch anomalies between GSTR-2A/2B and GSTR-3B, or due to suppliers failing to deposit taxes under Section 16(2)(c).
High-pitched, arbitrary tax demands levied on non-filers or unregistered entities under Sections 62 and 63 without accounting for actual turnover.
Complex litigations involving the wrong invocation of tax rates, circular ambiguities, or disputes on cross-charge vs. transfer pricing elements between distinct entities.
Sudden blocking of the Electronic Credit Ledger (Rule 86A), attachment of bank accounts, or cancellation of GST registrations, which completely stalls active business operations.
Protecting Your Cash Flow — by securing timely stay orders against tax demands, we prevent the department from executing coercive bank attachments, keeping your working capital safe. Uncompromising Timeliness — missing a GST limitation window can prove fatal to a business. We actively track your corporate tax portal, ensuring every single reply, pre-deposit payment, and appeal is executed with promptness. Operational Freedom — let our legal experts shoulder the burden of tax audits, personal hearings, and complex legal drafting. Your executive leadership can redirect 100% of their energy toward market expansion and corporate growth.
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Forensic review of every SCN, DRC-01, or Order-in-Original — jurisdiction, DIN, limitation, and substantive grounds.
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GSTR-1, 3B, 2A/2B, e-way bill, ICEGATE, and books reconciled invoice-by-invoice.
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Form GST APL-01 (First Appeal) or APL-05 (GSTAT) drafted with pre-deposit planning.
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Personal hearings at Adjudicating Authority, First Appellate Authority, and GSTAT benches.
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Stay applications, bank-attachment defence, and Rule 86A unblocking interventions.
Get in touch with our Retained Indirect Tax Counsel today to audit your current notices or prepare your appeals ahead of the June 30, 2026 GSTAT backlog deadline.