GST appeal pre-deposits: calculation, refunds and interest clarified

CBIC Circular 259/05/2026-GST, dated 26 October 2026, clarifies pre-deposits for GST appeals and their refund after a favourable order.

Admitted tax, interest, fine, fee and penalty must be paid in full. The ordinary first-appeal pre-deposit of 10% is calculated on disputed tax. For a further GSTAT appeal, the additional 10% deposit is calculated on the disputed tax remaining under the first appellate order, rather than mechanically using the original demand. Applicable statutory limits and special provisions still require checking.

A refund following a favourable order may be claimed through RFD-01 under the reason relating to an assessment, appeal or other order. The favourable order need not separately direct repayment of the pre-deposit. A departmental intention to appeal does not itself justify withholding a refund without a relevant stay.

Interest under section 115 must reflect the separate payment dates of deposits at different appeal stages. Remand and partial-remand cases require appropriate adjustments.

Businesses should reconcile each order, challan and disputed amount before filing an appeal or refund application and retain the complete payment trail.