# Delhi High Court Rejects Retrospective 10% GST Appeal Deposit 2026-08-06T21:51:40+00:00 | Governance | Indian Opinion Desk Corroboration: 1 independent outlet The Delhi High Court has ruled that a 10% pre-deposit requirement for appeals against penalty-only GST orders cannot apply to proceedings that began before October 1, 2025. The requirement was introduced through an amendment to Section 107(6) of the CGST Act. The court held that the right to appeal, including its conditions, takes shape when adjudication proceedings begin. The case involved two taxpayers who received show cause notices in June 2025 and later faced penalties exceeding Rs 346 crore each. The court directed the appellate authority to hear their appeals without demanding the 10% deposit. It said the taxpayers must still meet any admitted liability. The ruling is expected to aid penalty proceedings initiated before October 1, 2025, except those under Section 129, according to ETCFO. ## Coverage - cfo.economictimes.indiatimes.com Tags: CGST Act, Delhi High Court, GST, Tax appeals Canonical: https://indianopinion.org/delhi-high-court-rejects-retrospective-10-gst-appeal-deposit/ License: Summary and commentary (c) Indian Opinion, reusable with attribution. Facts belong to the linked sources. Cite: https://indianopinion.org/delhi-high-court-rejects-retrospective-10-gst-appeal-deposit/#story-in-brief Review state: restored archive article, accurate at time of publication, not offered to search indexes.