GSTAT has introduced an online mechanism allowing taxpayers with multiple GSTINs under the same PAN to file a single application for transferring appeals involving identical legal questions pending before different benches.
Based on Section 109(6) of the CGST Act, the mechanism aims to streamline litigation, reduce procedural burdens and minimise the risk of conflicting rulings. The move addresses widespread disputes, including 504 appeals concerning GSTAT’s power to condone delays.
The development also assumes significance as the GST taxpayer base has expanded to over 16.8 million as of July 2026, according to government data. However, GSTINs are issued on a state-wise basis, meaning a business operating across multiple states can hold several registra-tions under the same PAN.
The development is important as the GST taxpayer base has expanded to 16.8 million as of July 2026
Experts said that the new mechanism could help businesses with operations across several states, where mul-tiple GST registra-tions under the same PAN can lead to similar tax disputes being litigated before different GSTAT benches.
“The new transfer mecha-nism is particularly relevant for businesses with operations across several states, which may hold multiple GST registrations under the same PAN. A com-mon tax dispute involving the same legal provision can result in separate appeals before dif-ferent benches,” said Pankaj Dikshit, executive director and
chief AI and data officer, Cyg-net.One, a tax technology and financial digital transformation solutions provider.
The SOP provides a procedural route for such appeals to be brought together rather than requiring taxpayers to pursue separate transfer requests for each mat-ter, he said.
The mechanism could help reduce the possibility of diver-gent rulings on an identical question of law being decided by different GSTAT benches.
“The mechanism provides a structured way to deal with the same question of law arising in multiple appeals before differ-ent GSTAT benches. This can help reduce fragmented litiga-tion and the possibility of diver-gent views on the same legal issue, while ensuring that transfer requests are examined through a defined process,” said Vijay Kumar, partner, Fox Mandal, a law firm.
The statutory basis for the transfer mechanism is Section 109(6) of the CGST Act, under which the president of GSTAT can distribute the tribunal’s business among benches and transfer cases from one bench to another, subject to the appli-cable jurisdictional provisions.
Mint’s queries emailed to the Union finance ministry remained unanswered.
