Taxpayers have been facing difficulty in filing appeals on the GST portal where adjudication orders reflect “NIL” demand despite existence of a dispute regarding tax liability. This situation arises where payment of tax, interest, or penalty is made during the Show Cause Notice (SCN) stage without admission of liability, and the adjudicating authority issues an order treating such payment as full discharge. Consequently, the system records no liability, restricting appeal filing functionality.

Payment made during the SCN stage, without explicit admission of liability, does not amount to acceptance of the demand.

In such cases, the taxpayer retains the right to contest the liability and file an appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Where the adjudication order reflects a “NIL” demand incorrectly, the taxpayer is unable to file an appeal due to system restrictions on the GST portal.

In cases where a dispute regarding liability exists but is not captured in the demand order and payment has been made prior to issuance of the demand order, the taxpayer is required to approach the adjudicating authority for issuance of a rectification order.

Upon issuance of a rectification order reflecting the correct demand amount, the taxpayer may proceed to file an appeal on the GST portal within the prescribed time limits.