GSTN Advisory, GST (Portal / Appeal Filing / NIL Demand Orders), dated 03rd April 2026

GSTN has issued an advisory addressing a technical difficulty being faced by taxpayers attempting to file appeals on the GST portal against demand orders that reflect a “NIL” demand amount, despite an existing dispute regarding tax liability. This situation arises where a taxpayer makes payment of tax, interest, or penalty at the SCN stage without admitting liability, and the adjudicating authority thereafter issues a demand order treating such payment as full discharge without explicitly determining and recording the actual liability resulting in a Demand ID with zero value being created in the Demand and Collection Register (DCR). When the taxpayer subsequently attempts to file an appeal in Form APL-01, the portal blocks filing and displays an error stating “Disputed amount cannot be more than demand amount itself,” effectively effectively restricting the ability to file an appeal on the portal, GSTN has clarified that payment made during the SCN stage without explicit admission of liability does not amount to acceptance of the demand, and the taxpayer retains the full right to contest the liability. As an interim solution, taxpayers in such situations are advised to approach the adjudicating authority for issuance of a rectification order through the rectification option available on the GST portal, so that the correct demand amount is reflected in the system upon receipt of which the taxpayer may proceed to file the appeal within the prescribed time limits.