In a major relief to GST taxpayers, the Goods and Services Tax Network (GSTN) has enabled a new functionality on the GST portal allowing taxpayers to file online appeals against GST Amnesty Scheme rejection orders issued in Form SPL-07. This move empowers taxpayers whose applications were rejected under Section 128A to seek reconsideration through an appellate process.
🔍 Understanding the GST Amnesty Scheme Appeal Mechanism
Under the GST Amnesty Scheme, eligible taxpayers were required to file waiver applications using SPL-01 or SPL-02 forms by June 30, 2025, after clearing pending dues by March 31, 2025. Upon scrutiny, authorities could:
- Approve the application and issue Acceptance Order (SPL-05), or
- Reject it and issue Rejection Order (SPL-07).
Until now, there was no system to file an appeal against the SPL-07 rejection. However, as per the GSTN advisory dated July 16, 2025, taxpayers can now file an online appeal using Form APL-01 against this rejection.
✅ Key Highlights of the GSTN Advisory (16th July 2025)
- Appeal Filing Enabled: Taxpayers can now file appeal applications (APL-01) against SPL-07 (Waiver Rejection Orders) on the GST Portal.
- Navigation to File Appeal:
- Go to Services → User Services → My Application
- Select Application Type: “Appeal to Appellate Authority”
- Click New Application
- Under Order Type, choose: “Waiver Application Rejection Order”
- Fill in the required details and submit the appeal.
- No Withdrawal Option: Once an appeal under the waiver scheme is filed, it cannot be withdrawn through the portal. Hence, taxpayers are strongly advised to file such appeals cautiously.
- Restoration of Original Appeal: If a taxpayer doesn’t file an appeal against SPL-07 and had previously withdrawn the original appeal to opt for the amnesty, the original appeal shall be restored automatically under Rule 164(15)(a) after the appeal time expires under Section 107.
- Filing an Undertaking (SPL-08): This is only required if:
- The appeal against SPL-07 is rejected, and
- The taxpayer wishes to restore the original appeal (Rule 164(15)(b)(ii)).
🔄 Process Flow of GST Amnesty Scheme Orders
- SPL-01 / SPL-02: Initial waiver applications filed after tax dues payment.
- SPL-03: Show Cause Notice issued within 3 months if the department finds issues.
- SPL-04: Taxpayer must respond within one month.
- SPL-05: Acceptance order issued if reply is satisfactory.
- SPL-07: Rejection order issued if reply is unsatisfactory.
- APL-01: Taxpayer can now file appeal online against SPL-07.
- SPL-06: Issued if appeal is accepted by Appellate Authority.
- SPL-08: Undertaking filed if taxpayer doesn’t wish to pursue further appeals after SPL-07 rejection.
⚖️ What This Means for Taxpayers
This update brings critical procedural relief, especially for small businesses and consultants who applied under the GST Amnesty Scheme in good faith but faced rejections. Now, such taxpayers can challenge the SPL-07 rejection orders within 3 months and pursue legitimate remedies without losing their right to defend against prior tax demands.
Even if you miss the appeal deadline, your original appeal will be restored automatically under Rule 164(15)(a). Filing an undertaking is only required if your appeal against the SPL-07 is rejected and you wish to revive your original appeal.
💡 Key Takeaways
- Appeals against SPL-07 rejections are now officially enabled on the GST Portal.
- Exercise caution while filing waiver scheme appeals—no withdrawal is allowed.
- You still have the right to restore your original appeal even if your waiver appeal fails.
- Undertakings (SPL-08) are needed only after appellate rejection, not immediately upon SPL-07.
🔔 Stay Compliant, Stay Updated
With this welcome change, the government has taken another step toward simplifying GST dispute resolution. Taxpayers are advised to check their application status and file appeals within the permitted timeline to avoid adverse orders and penalties.
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