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Circular No. 250/07/2025: Review & Appeal of CAA Orders

by Shakshi Bharti | Jul 16, 2025 | GST, Circulars | 0 comments

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Important Keyword: Notification No. 23/2023 - Integrated Tax (Rate), Common Adjudicating Authority, GST Appeal Process, GST Revision, GST Review Authority, DGGI SCN, CAA Orders, GST Legal Procedure, GST Circular 250/07/2025,

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F. No. CBIC-20010/22/2025-GST
Government of India
Ministry of Finance
Department of Revenue
Central Board of Indirect Taxes and Customs GST Policy Wing

North Block, New Delhi Dated: 24^th June, 2025

Circular No. 250/07/2025 - GST: Reviewing authority, Revisional Authority and Appellate Authority in respect of orders passed by Common Adjudicating Authority (CAA) for show cause notices issued by DGGI

To,

The Principal Chief Commissioners/ Chief Commissioners (All) The Principal Director General/ Director General (All) Madam/Sir,

Subject: Reviewing authority, Revisional Authority and Appellate Authority in respect of orders passed by Common Adjudicating Authority (CAA) for show cause notices issued by DGGI - reg.

Attention is drawn to notification No. 02/2017 dated 19^th June 2017 (as amended) read with circular No. 239/33/2024-GST dated 04^th December 2024, wherein Joint/Additional Commissioners posted in specified Commissionerate's have been designated as Common Adjudicating Authority (CAA) in respect of show cause notices issued by Directorate General of GST Intelligence (DGGI). The said circular has specified the procedure to be followed in case of assigning such show cause notices to the Common Adjudicating Authority along with their territorial jurisdiction. However, it does not specify the procedure related to review, revision, and appeals for such Orders-in -Original (O-I-Os) passed by CAA.

The matter has been examined in consultation with the Union Ministry of Law and Justice which has clarified that section 107 of the CGST Act, 2017 provides a detailed mechanism for handling the appeals by the Appellate authority and by exercising the same power, the rules have also been framed with regard to appeal and review. Similarly, the Reviewing Authority also has the power under the said section to review adjudication orders passed by a CAA who is posted under the said reviewing authority.

Similarly, section 108 of the CGST Act, 2017, provides a detailed mechanism for revision of such orders. Vide notification No. 05/2020-Central tax dated 13^th January, 2020, the jurisdictional Principal Commissioner or Commissioner, as the case may be, has been authorized as revisional authority for decisions or orders passed by Additional or Joint Commissioner of Central Tax who are subordinate to him.
Therefore, to ensure uniformity in procedure for review, revision, and appeal against the Orders-in-Original (O-I-Os) adjudicated by Common Adjudicating Authorities, it is hereby clarified that:
- Review under Section 107 of the CGST Act, 2017: The Principal Commissioner or Commissioner of Central Tax under whom the Common Adjudicating Authority (Additional/ Joint Commissioner) is posted shall be the reviewing authority in respect of such O-I-Os.
- Revisional Power under Section 108 of the CGST Act, 2017: The Principal Commissioner or Commissioner of Central Tax under whom the Common Adjudicating Authority (Additional/ Joint Commissioner) is posted shall be the revisional authority in respect of such O-I-Os.
- Appeal Procedure under Section 107 of the CGST Act, 2017: Appeals against the order of Common Adjudicating Authority (Additional/Joint Commissioner) shall lie before the Commissioner (Appeals) corresponding to the territorial jurisdiction of the Principal Commissioner or the Commissioner of Central Tax, under whom the said Common Adjudicating Authority (Additional/ Joint Commissioner) is posted, as specified in Table III of notification No. 02/2017- Central tax dated 19^th June, 2017.
- Department's Representation in Appeals: The Principal Commissioner or Commissioner of Central Tax of such Commissionerate under whom the Common Adjudicating Authority (Additional/Joint Commissioner) is posted shall represent the department in appeal proceedings against the O-I-Os passed by such Common Adjudicating Authority (Additional/ Joint Commissioner) and accordingly may appoint any officer subordinate to him to be the designated officer for filing departmental appeals.
- The reviewing or revisional authority for such orders may seek comments on the O-I-O from the concerned DGGI formation before proceeding to decide on the order passed by the CAA.
It is requested that suitable trade notices may be issued to publicize the contents of this circular.
Difficulty, if any, in the implementation of the above instructions may please be brought to the notice of the Board.

Yours faithfully,
(Gaurav Singh)
Commissioner (GST)

📚 Frequently Asked Questions (FAQs): Circular No. 250/07/2025 - GST

Q1: What is Circular No. 250/07/2025 – GST all about?

Answer:
Circular No. 250/07/2025 clarifies the authorities responsible for review, appeal, and revision of orders passed by the Common Adjudicating Authority (CAA), specifically in cases where show cause notices (SCNs) have been issued by the Directorate General of GST Intelligence (DGGI).

Q2: Who is designated as the Reviewing Authority for CAA orders under GST?

Answer:
The Principal Commissioner or Commissioner of Central Tax, under whom the CAA (Joint/Additional Commissioner) is posted, is designated as the Reviewing Authority as per Section 107 of the CGST Act, 2017.

Q3: What is the Revisional Authority for CAA orders under this circular?

Answer:
As per Section 108 of the CGST Act, the Principal Commissioner or Commissioner under whom the CAA is posted acts as the Revisional Authority.

Q4: Where should an appeal against a CAA order be filed?

Answer:
Appeals against Orders-in-Original (O-I-Os) passed by CAAs are to be filed before the Commissioner (Appeals) corresponding to the jurisdiction of the Principal Commissioner/Commissioner supervising the CAA.

Q5: How is the department represented during appeals of CAA orders?

Answer:
The Principal Commissioner or Commissioner overseeing the CAA appoints an officer subordinate to them to represent the department in appeals against CAA orders.

Q6: Can DGGI provide input during the review or revision process?

Answer:
Yes. The reviewing or revisional authority may consult the concerned DGGI formation and seek their comments before making a decision on an O-I-O passed by the CAA.

Q7: What triggered the issuance of Circular 250/07/2025?

Answer:
The need arose from the absence of specified procedures in earlier circulars regarding the review, revision, and appeal of CAA orders, prompting this comprehensive clarification.

Q8: Which notifications and sections are referenced in this circular?

Answer:
It references Notification No. 02/2017, Circular No. 239/33/2024-GST, Notification No. 05/2020-CT, and Sections 107 & 108 of the CGST Act, 2017.

Q9: How should businesses act on this update?

Answer:
Businesses involved in DGGI-issued SCNs should ensure their tax teams or GST consultants are aware of the clarified procedures to ensure smooth legal compliance. 🔗 Need assistance? Connect with a GST Expert via www.Finodha.in.