CBIC Clarifies Review, Revision, and Appeal Procedures for Orders Passed by CAAs under DGGI
By Author | June 24, 2025
Introduction
The Central Board of Indirect Taxes and Customs (CBIC), through Circular No. 250/07/2025-GST dated June 24, 2025, has clarified procedures related to the review, revision, and appeal of orders issued by Common Adjudicating Authorities (CAAs). These CAAs handle show cause notices from the Directorate General of GST Intelligence (DGGI).
Review and Revisional Authority
The Principal Commissioner or Commissioner of Central Tax, who supervises the posted CAA (Additional/Joint Commissioner), will serve as the reviewing and revisional authority for Orders-in-Original (O-I-Os).
Furthermore, before making a decision, the reviewing or revisional authority may consult the relevant DGGI formation for input on the order.
Appellate Jurisdiction and Representation
Appeals will be filed before the Commissioner (Appeals), who has territorial jurisdiction over the area where the CAA operates.
In such appeal cases, the Principal Commissioner or Commissioner will represent the department. If needed, they may appoint a subordinate officer for this task.
Background and Legal Framework
Previously, Notification No. 02/2017 (June 19, 2017) and Circular No. 239/33/2024-GST (December 4, 2024) designated certain Joint/Additional Commissioners as CAAs to adjudicate show cause notices from DGGI. However, these notifications did not address procedures for review, revision, or appeal of the resulting orders.
To clarify this gap, CBIC consulted the Union Ministry of Law and Justice, which confirmed that the CGST Act, 2017 already provides the legal basis under:
- Section 107 – Appeals and Reviews
- Section 108 – Revision of Orders
Additionally, Notification No. 05/2020-Central Tax (January 13, 2020) authorized jurisdictional Principal or Commissioners to act as revisional authorities for orders passed by their subordinate officers.
Summary of CBIC Clarifications
To ensure uniformity, CBIC has issued the following directions:
a) Review under Section 107
The Principal Commissioner/Commissioner supervising the CAA will conduct reviews of all O-I-Os issued.
b) Revision under Section 108
The same official will exercise revisional powers over those orders.
c) Appeal Jurisdiction
Appeals must be filed before the Commissioner (Appeals) of the region linked to the supervising Principal Commissioner/Commissioner, as listed in Table III of Notification No. 02/2017.
d) Departmental Representation
In all appeals, the department will be represented by the supervising officer or a designated subordinate.
e) DGGI Consultation
Before finalizing any review or revision, the Commissioner may seek feedback from the DGGI formation concerned with the order.
Instructions to Field Officers
CBIC has instructed all field offices to issue trade notices to raise awareness about these procedural updates. These steps will help ensure that taxpayers and GST practitioners understand the revised framework.
If any issues occur during implementation, officers should report them directly to the CBIC.
