NIL Demand Orders, Portal Glitches and the Vanishing 90 Days: A Silent Threat to GST Appeals
The GST Network has recently acknowledged a serious technical issue that directly affects a taxpayer’s right to appeal under section 107 of the CGST Act. Many taxpayers are finding themselves unable to file appeals on the portal where the adjudication order shows a “NIL” demand, even though a genuine dispute on tax liability still exists. This situation typically arises when a taxpayer makes payment of tax, interest or penalty at the Show Cause Notice (SCN) stage. Such payments are often made to avoid further litigation, interest or coercive recovery, and do not necessarily amount to admission of liability. Yet, when the final order is passed, adjudicating authorities sometimes mechanically treat this pre‑deposit as full satisfaction of demand and record the liability as completely discharged. The result: the order reflects a “NIL” demand. Once the order shows NIL, the GST portal auto‑populates the Demand and Collection Register with “zero” liability. When the taxpayer then attem...