The university, in a 14-page rebuttal released Tuesday, spelled out several reasons why the wins should be restored, including the NCAA committee on infraction's improper citing of Alabama's repeat offender status.
The university said no other textbook case led to wins being vacated and that the committee's brief failed to mention even one textbook case to use for comparison.
A call to an NCAA spokeswoman seeking comment was not immediately returned.
The case that led to Alabama's penalty involved 201 athletes in 16 sports obtaining textbooks they weren't entitled to under their scholarships. The violators included 22 "intentional wrongdoers"
-- among them seven football players -- who obtained more than $100 in supplies for other students.
Alabama was placed on three-year probation in June, fined $43,900 and also forced to vacate one postseason tennis victory and several individual and team records in track and field.
Alabama's appeal said the penalty vacating football victories was "so excessive as to constitute an abuse of discretion."
The rebuttal, dated Sept. 17 but not made public until Tuesday, said the NCAA described Alabama as having an "abysmal" history of infractions and that the university's poor record was "the driving force behind" the penalty vacating the football victories.
The university argued that the repeat violator status shouldn't have been a factor and that the committee cited it in a way that "ignores bylaws and precedent addressing repeat violator penalties."
According to Alabama, the NCAA said the university's "extensive recent history of infractions cases is unmatched by any other member institution in the NCAA." Alabama said the NCAA database includes at least 27 Football Bowl Subdivision schools with as many or more infractions cases.