Counting the 60-Day Window After a GSTAT Appeal Token Is Generated

This article examines how the 60-day period for completing an appeal is to be reckoned once a token has been generated under Order No. 156/2026 dated 10 July 2026 of the President, GSTAT, issued under Rule 123 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025.

The point matters now because tokens may be obtained only up to 31 July 2026, and the filing window that follows is short. A token that appears to lapse a few hours earlier than the law allows can cost an appellant the appeal under Section 112 of the CGST Act, 2017, so the expiry date should be fixed on principle and not left to what a portal displays.

Issue

Order No. 156/2026 lets an appellant record an intention to appeal by obtaining a token on or before 31 July 2026 and then complete filing "within a period of 60 days from the date of token generation." Paragraph 3 treats timely token generation as sufficient for the due date, subject to filing within the allowed period. An accompanying advisory says that the token lapses "after 60 days of its generation" and that the date and time of generation are recorded.

Three questions follow:

  • whether the period is measured by calendar days or by elapsed time from the recorded timestamp;
  • whether the preposition "of" in the advisory differs in effect from "from" in the Order;
  • whether recording the time of generation fixes the time of expiry.

General limitation for appeals before the Tribunal is a separate subject and is not dealt with here.

Governing provisions

Rule 3 of the GSTAT (Procedure) Rules, 2025 (notified by G.S.R. 256(E) dated 24 April 2025, in force from notification) governs computation of time. It applies to periods prescribed by the relevant laws and rules and also to periods fixed by the Appellate Tribunal for the doing of an act. Its operative direction is that "the day from which the said period is to be reckoned shall be excluded". Rule 3 also deals separately with closure of the Tribunal's office on the last day.

Rule 123 deals with difficulties and with matters on which the Rules are silent. Computation of time is not a silent matter, because Rule 3 covers it, so Rule 123 is not the source of the counting method.