On 1 May 2001, a five-judge Constitution Bench of the Supreme Court affirmed the Shambhu Nath Goyal threshold-pleading rule — management must, at the first opportunity in its written statement before the Tribunal, reserve the right to lead fresh evidence in the event the domestic enquiry is found invalid.
The GST Appellate Tribunal was statutorily provided for in 2017 but operationally inert for nearly eight years. The notification of the GSTAT (Procedure) Rules, 2025 on 24 April 2025 — followed by GSTAT becoming operational from September 2025 — has produced an institutional architecture that the GST framework had been missing since inception. The 30 June 2026 special backlog cutoff is the most urgent practitioner item. A digest of the Rules, the operational architecture, and the timeline practitioners must be tracking.