Mandatory 10% Pre-Deposit For GST Penalty Appeals Inapplicable To Cases Initiated Prior To Oct 2025 Amendment: Delhi High Court

The Delhi High Court has held that the mandatory 10% pre-deposit requirement for filing appeals against penalty-only orders, introduced under the substituted proviso to Section 107(6) of the Central Goods and Services Tax (CGST) Act with effect from October 1, 2025, cannot be applied retrospectively to proceedings initiated prior to the amendment. The Court held that the right of appeal is a subst…