Updated: 15 September 2026

Section 111 of CGST Act: Procedure Before Appellate Tribunal

Section 111 of the Central Goods and Services Tax Act, 2017 lays down the procedural powers of the Goods and Services Tax Appellate Tribunal (GSTAT). It makes natural justice the governing procedural principle, gives the Tribunal specified powers of a civil court, provides for execution of Tribunal orders and treats Tribunal proceedings as judicial proceedings.

On this page

Meaning and scope of Section 111
Section 111 - statutory provision
Sub-section-wise explanation
GSTAT Procedure Rules, 2025
Related CGST appeal provisions

What does Section 111 of the CGST Act provide?

Section 111 is the principal procedural provision governing proceedings before the Appellate Tribunal under the CGST Act. The Tribunal is not bound by the procedure in the Code of Civil Procedure, 1908 while disposing of proceedings or appeals. Instead, it is guided by the principles of natural justice, remains subject to the CGST Act and the rules made under it, and may regulate its own procedure.

The section nevertheless confers specified civil-court powers on the Tribunal, including powers relating to attendance of persons, discovery and production of documents, affidavit evidence, public records, commissions, default and ex parte proceedings. It also provides a mechanism for enforcing Tribunal orders.

Key point: Section 111 combines procedural flexibility with judicial safeguards. GSTAT is not tied to every technical rule of the CPC, but it must comply with natural justice, the CGST Act and applicable rules.

Section 111 - Procedure before Appellate Tribunal

(1) The Appellate Tribunal shall not, while disposing of any proceedings before it or an appeal before it, be bound by the procedure laid down in the Code of Civil Procedure, 1908, but shall be guided by the principles of natural justice and, subject to the other provisions of the Act and the rules made thereunder, shall have power to regulate its own procedure.

(2) For discharging its functions under the Act, the Appellate Tribunal has the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 while trying a suit in respect of the following matters:

(a) summoning and enforcing the attendance of any person and examining that person on oath;

(b) requiring discovery and production of documents;

(d) subject to sections 123 and 124 of the Indian Evidence Act, 1872, requisitioning a public record or document, or a copy thereof, from any office;

(e) issuing commissions for examination of witnesses or documents;

(f) dismissing a representation for default or deciding it ex parte;

(g) setting aside an order dismissing a representation for default or an order passed ex parte; and

(h) any other matter that may be prescribed.

(3) An order made by the Appellate Tribunal may be enforced in the same manner as if it were a decree made by a court in a pending suit. The Tribunal may send its order for execution to the court within whose local jurisdiction the registered office of a company is situated, or, for any other person, where that person voluntarily resides, carries on business or personally works for gain.

(4) Proceedings before the Appellate Tribunal are deemed to be judicial proceedings for the purposes stated in Section 111(4), and the Tribunal is deemed to be a civil court for the purposes specified in that sub-section.

Current-law reading note: The enacted text of Section 111 continues to contain references to the Indian Evidence Act, 1872, the Indian Penal Code, 1860 and the Code of Criminal Procedure, 1973. Those three general laws were replaced from 1 July 2024 by the Bharatiya Sakshya Adhiniyam, 2023, Bharatiya Nyaya Sanhita, 2023 and Bharatiya Nagarik Suraksha Sanhita, 2023 respectively. The statutory wording of Section 111 should therefore be read together with the applicable repeal, savings and corresponding-law provisions rather than silently rewriting the text of Section 111.

Section 111 explained sub-section by sub-section

1. Natural justice and power to regulate procedure - Section 111(1)

GSTAT is not required to follow the CPC as though it were an ordinary civil court. Its procedure must, however, remain fair. In practical terms, the principles of natural justice ordinarily require a meaningful opportunity of hearing, impartial adjudication and a fair procedure consistent with the Act and applicable rules.

2. Civil court powers - Section 111(2)

The Tribunal receives specific powers comparable to those exercised by a civil court while trying a suit. These powers support fact-finding and effective adjudication, including compelling attendance, obtaining documents, accepting affidavit evidence and dealing with default or ex parte proceedings.

Power	Practical effect
Summons and attendance	The Tribunal can require a person to appear and may examine the person on oath.
Discovery and documents	Relevant documents may be required to be discovered and produced.
Affidavit evidence	Evidence may be received by affidavit where procedurally appropriate.
Public records	The Tribunal may requisition public records subject to the statutory limitations referred to in Section 111(2)(d).
Commissions	Commissions may be issued for examination of witnesses or documents.
Default and ex parte orders	A matter may be dismissed for default or decided ex parte, with power to set aside such orders.

3. Execution of GSTAT orders - Section 111(3)

A Tribunal order is not merely declaratory. Section 111(3) gives it an execution mechanism comparable to a civil court decree and identifies the court to which the Tribunal may send the order for execution based on the location of the company or other person concerned.

4. Judicial character of proceedings - Section 111(4)

This provision gives proceedings before GSTAT a statutory judicial character for the purposes specified in the section. It reinforces the seriousness of evidence, statements and conduct in Tribunal proceedings.

GSTAT Procedure Rules, 2025

Section 111 must now be read in the operational setting of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025. These rules govern Tribunal practice and procedure, including sittings, filing, scrutiny, listing, Registrar functions and procedural applications. The rules also recognize the Tribunal's inherent procedural powers and its ability, in appropriate cases, to exempt compliance or extend time as permitted by the rules.

For actual filing, parties should verify the latest directions, Presidential Orders, bench arrangements, e-filing instructions and notices on the official GSTAT portals before taking procedural steps.

Disclaimer: This page is a general legal information resource. Tribunal procedure may also depend on amendments, notifications, rules, Presidential Orders, bench-specific directions and facts of the case. Verify the current official text before filing or acting on a GST appeal.