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Circular No. 250/07/2025-GST
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
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 Commissionerates 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.
2. 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.

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3. 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.
4. 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:
a) 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.
b) 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.
c) 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.
d) 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.

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e) 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.
5. It is requested that suitable trade notices may be issued to publicize the contents of this
circular.
6. 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)