GSTAT Appeal Token: Calculating the 60-Day Filing Period Under Order No. 156/2026

Introduction: A Deceptively Simple Arithmetic Question

When the Goods and Services Tax Appellate Tribunal introduced its token-based appeal facility, it opened a practical question that sits at the intersection of procedural law and everyday arithmetic. If an appellant generates a token at 4 p.m. on a particular date, does the 60-day filing window close at exactly 4 p.m. on the sixtieth day — amounting to precisely 1,440 hours — or does the appellant retain the benefit of the entire sixtieth calendar day, right up to midnight?

The answer is not merely a matter of convenience. It determines whether an appeal filed at, say, 6 p.m. on the last day is timely or time-barred. This article examines the governing legal framework — Order No. 156/2026, its accompanying advisory, Rule 3 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025, Section 9 of the General Clauses Act, 1897, and a series of Supreme Court decisions — to arrive at a principled conclusion on how the 60-day period must be computed.

The GSTAT Token Facility: Background and Governing Text

What Order No. 156/2026 Says

Order No. 156/2026 dated 10 July 2026, issued by the President, GSTAT, in exercise of powers under Rule 123 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025, established a token mechanism for appeals filed under Section 112 of the CGST Act, 2017.

The core operative provision in Paragraph 2 allows an assessee to register the intention to appeal by obtaining a token on or before 31 July 2026, and then to complete the full filing:

"within a period of 60 days from the date of token generation."

Paragraph 3 of the order treats timely generation of the token as adequate compliance with the due date requirement for filing, provided that the actual filing is completed within the permitted period.

The advisory attached to the order adds a further dimension. It states that the token will lapse "after 60 days of its generation" and also provides for the recording of both the date and the time of token generation.

It is this combination — the order's use of "from the date", the advisory's use of "of its generation", and the recording of a specific timestamp — that creates the interpretive question at the heart of this discussion.

Do "Of" and "From" Carry Different Meanings Here?

Before turning to the computation rules, it is worth addressing whether the slightly different wording in the order ("from the date of token generation") and the advisory ("after 60 days of its generation") produces different legal consequences.

In Econ Antri Ltd. v. Rom Industries Ltd., (2014) 11 SCC 769, decided on 26 August 2013, a three-Judge Bench of the Supreme Court examined precisely this question. Paragraph 22 of that decision states:

"the words 'of', 'from' and 'after' may, in a given case, mean really the same thing."

Since the order and the advisory both pertain to the identical period and serve the same purpose — defining how long an assessee has to complete filing after obtaining a token — there is no basis for treating these expressions as pointing to different computation methods. The advisory elaborates on the order; it does not override it or introduce a separate clock-based expiry.

The Court's rider that context remains relevant is important. But in the present context, neither expression explicitly directs that expiry be calculated to the precise hour and minute of generation. Absent such a direction, both expressions should receive the same effect.

Rule 3 of the GSTAT (Procedure) Rules, 2025: The Mandatory Computation Framework

The Express Statutory Provision

Rule 3 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025, notified vide G.S.R. 256(E) dated 24 April 2025, is the pivotal provision. It governs the computation of periods prescribed both by the relevant laws and rules, and by periods fixed by the Appellate Tribunal itself for the performance of any act. Its operative direction is unambiguous:

"the day from which the said period is to be reckoned shall be excluded"