🧾 Govt Eases GST Amnesty Scheme: What You Must Know Before March 31, 2025
With just days left before the crucial March 31, 2025 deadline for making GST tax payments under the GST Amnesty Scheme, the government has stepped in with last-minute amendments to address genuine difficulties faced by registered taxpayers. These changes, brought through Notification No. 11/2025 – Central Tax and CBIC Circular No. 248/05/2025-GST, aim to remove ambiguity and provide operational clarity for cases involving GSTR-3B payments and appeals spanning multiple tax periods.
Let’s break down the key updates and how they impact your eligibility under Section 128A of the CGST Act.
🔍 What Changed in the GST Amnesty Scheme?
✅ Amendment 1: Appeals Now Deemed Withdrawn for 2017–2020
If your GST tax appeal spans multiple years—some eligible under the Amnesty Scheme and some not—the appeal will be deemed withdrawn only for FY 2017-18 to 2019-20, provided you pay full tax dues for these years. You can still pursue appeals for the remaining years.
📌 Legal Reference: Rule 164(4) & Proviso to Rule 164(7) amended
📜 Official Notification: Notification No. 11/2025-Central Tax
🧑⚖️ Case Law Insight: Union of India vs. VKC Footsteps India Pvt. Ltd. – reinforced the principle of legislative intent behind transitional relief in GST matters.
✅ Amendment 2: GSTR-3B Payments Prior to Nov 1, 2024 Are Eligible
One major taxpayer concern was around payments made through GSTR-3B instead of DRC-03. The CBIC has now clarified that any tax demand amount paid via GSTR-3B before November 1, 2024 (the date Section 128A came into force) will be considered valid for amnesty eligibility—subject to verification by the proper officer.
📌 Circular Reference: CBIC Circular No. 248/05/2025-GST
This clarification bridges a real compliance gap. Earlier, only DRC-03 was accepted. Now, even GSTR-3B payments qualify—this can save hundreds of businesses.” — CA Deep Koradia
📅 Two Key GST Amnesty Deadlines You Must Track
| Deadline | Action Required |
|---|---|
| March 31, 2025 | Pay full GST tax dues (without interest & penalty) |
| June 30, 2025 | File Amnesty application (FORM SPL-01 or SPL-02) |
📌 Summary Table: Who Is Eligible & What to Do
| Case | Due Date for Payment | Mode of Payment | Form to File | Amnesty Application Deadline |
|---|---|---|---|---|
| Notice issued, no adjudication | 31-03-2025 | DRC-03 | SPL-01 | 30-06-2025 |
| Order passed, no appeal | 31-03-2025 | E-Liability Register | SPL-02 | 30-06-2025 |
| OIA passed, no Tribunal | 31-03-2025 | E-Liability Register | SPL-02 | 30-06-2025 |
| Redetermined order u/s 73 | 6 months | E-Liability Register | SPL-02 | 6 months |
| Revision leads to added tax | 3 months | E-Liability Register | SPL-02 | 3 months |
Source: A2Z Taxcorp LLP
🧠 Expert Analysis: Why These Amendments Matter
💡 CA Bimal Jain:
“This was much-needed. Taxpayers were caught in technicalities. Now, even if the payment was made via GSTR-3B before Nov 1, 2024, they are safe.”
💡 CA Pradeep Reddy, Unnathi Partners:
“You don’t need to withdraw the whole appeal anymore. Just inform the appellate authority you’re claiming relief under 128A for eligible years.”
💬 FAQ Section (Structured Data Ready)
Q1. I paid my GST dues via GSTR-3B in October 2024. Can I still apply under Section 128A?
Yes, as clarified by CBIC, payments made via GSTR-3B before November 1, 2024, are valid for amnesty—subject to verification.
Q2. What if my tax demand includes FY 2019-20 and FY 2020-21?
You can split your payment. Pay for FY 2019-20 to claim amnesty and continue your appeal for FY 2020-21.
Q3. Do I need to withdraw my entire GST appeal?
No. You only need to inform the authority that you’re not pursuing the appeal for the FYs covered under Section 128A.
Q4. Will I get a refund if I already paid dues for FY 17-18 to 19-20?
No. The amendment clearly states that no refund will be issued if the full amount was already paid.
📲 Key Takeaways (Perfect for Repurposing)
Tweet Thread/LinkedIn Post Ideas:
- 🚨 Govt clarifies GST Amnesty Scheme: Now GSTR-3B payments (pre-Nov 1, 2024) are valid!
- 💼 Appeals no longer need full withdrawal—just inform authority!
- 📅 March 31, 2025: Deadline to pay dues for 17-18 to 19-20
- ✅ No more confusion. File SPL-01/02 by June 30, 2025.
- 🔁 RT to alert business owners and tax professionals!
💼 Who Should Act Now?
- Business Owners with past GST notices for FY 2017-18 to 2019-20
- Tax Professionals advising clients on GST appeals
- Compliance Officers handling GST litigation
- Freelancers or Startups who want to close legacy GST issues before new filings
🔚 Final Word from Efiletax
The government has shown flexibility in implementing the GST Amnesty Scheme, addressing real-world challenges. If your GST demand falls within FY 2017-20, don’t wait. Pay your dues before March 31, 2025 and file your application by June 30, 2025.
Need expert help? Reach out to Efiletax.in for smooth filing under the GST Amnesty Scheme!