Chapter XVIII - Appeals and revision
Section 121
Section 121: Non-appealable decisions and orders
Four categories of central tax officer decisions are excluded from the Act’s appeal routes.
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Need advice on Section 121?
This article is for general information. Refer to the Central Goods and Services Tax Act, 2017 official text for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
Notwithstanding anything to the contrary in any provisions of this Act, no appeal shall lie against any decision taken or order passed by an officer of central tax if such decision taken or order passed relates to any one or more of the following matters, namely:— (a) an order of the Commissioner or other authority empowered to direct transfer of proceedings from one officer to another officer; or (b) an order pertaining to the seizure or retention of books of account, register and other documents; or (c) an order sanctioning prosecution under this Act; or (d) an order passed under section 80.
Key takeaways
Transfer of proceedings
An order directing transfer of proceedings from one officer to another is non-appealable.
Records and prosecution
An order on seizure or retention of books and documents, or sanctioning prosecution, is excluded.
Instalment order
A section 80 order on payment by instalments is also excluded.
Transfer of proceedings
An order directing transfer of proceedings from one officer to another is non-appealable.
Records and prosecution
An order on seizure or retention of books and documents, or sanctioning prosecution, is excluded.
Instalment order
A section 80 order on payment by instalments is also excluded.
Practical checklist
Do
- Classify the exact operative decision.
- Compare it with section 121(a)-(d).
- Seek case-specific advice on any separate remedy.
Frequently asked questions
Is a section 80 instalment order appealable under the CGST Act?
No. Section 121(d) lists that order as non-appealable.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026