GST Appeal Filing Against SPL-07 Orders: What Taxpayers Must Know
The GST appeal filing against SPL-07 orders is now active on the GST Portal from 16 July 2025, as per GSTN Advisory No. 615. Taxpayers who received rejection orders (SPL-07) under the amnesty-like waiver scheme can now file Form APL-01 appeals online.
Background: Waiver Scheme Under Section 128A
The waiver scheme under Section 128A of the CGST Act, 2017 was launched to help taxpayers settle old disputes by waiving interest and penalties, primarily for FY 2017-18 to 2019-20.
- Forms SPL-01/SPL-02: Used to apply for waiver
- Form SPL-05: Indicates acceptance of waiver
- Form SPL-07: Rejection of waiver application
- Form APL-01: Used to appeal against rejection (now enabled for SPL-07)
Key Features of APL-01 Appeal Filing Against SPL-07
1. Appeals Enabled on GST Portal
Taxpayers can now file APL-01 electronically against SPL-07 orders. This offers a structured route to challenge the rejection of waiver claims.
2. One-Way Filing – No Withdrawal Allowed
As per Advisory No. 615:
- This is unlike certain other appeal types (e.g., against DRC-07) which may allow withdrawal before admission.
3. Legal Implication of Non-Withdrawal
This clause signals greater legal scrutiny. You must ensure:
- All facts are clear
- Documents are complete
🟠 Expert View:
Weak appeals can hurt your case later,” says a senior GST consultant from Chennai.
Step-by-Step: How to File APL-01 Against SPL-07
| Step | Action |
|---|---|
| 1 | Log in to GST Portal |
| 2 | Navigate to Services → User Services → My Applications |
| 3 | Select Appeal to Appellate Authority (APL-01) |
| 4 | Choose the SPL-07 order reference |
| 5 | Fill in grounds of appeal, attach documents |
| 6 | Submit appeal and track status in dashboard |
Strategic Considerations Before Filing
- Assess Tax Liability: Appeals are only allowed if full tax dues are already paid as per the scheme.
- High-Value Risk: 30% of SPL-07 rejections in 2024 were linked to disputes over ₹500 crore – these attract department attention.
- Avoid Frivolous Appeals: Filing without merit can backfire legally and financially.
Comparison: Appeal Against SPL-07 vs DRC-07
| Feature | SPL-07 Appeal | DRC-07 Appeal |
|---|---|---|
| Form Used | APL-01 | APL-01 |
| Online Filing | Yes | Yes |
| Withdrawal Allowed | No | Sometimes |
| Linked to Waiver Scheme | Yes | No |
| Strategic Filing Needed | High | Moderate |
Legal Reference
- GSTN Advisory No. 615 dated 16.07.2025
- Section 128A, CGST Act, 2017 (inserted via Finance Act, 2024)
- Official GST Portal
FAQs
Q1: Can I modify my APL-01 once filed?
No. Once submitted, modifications or withdrawals are not allowed against SPL-07 orders.
Q2: Is there a fee for filing this appeal?
Yes, as per standard APL-01 procedures — calculated based on disputed amount.
Q3: Can I file appeal if partial tax is paid?
No. Waiver scheme eligibility requires full tax payment upfront.
Q4: Is there a deadline to file APL-01 against SPL-07?
Yes. Usually 3 months from date of order, but verify based on portal date.
Final Word
The activation of GST appeal filing against SPL-07 orders is a welcome relief — but it comes with serious implications. No withdrawal means no second chances. If you’re filing an appeal, get expert help, prepare thoroughly, and ensure your claim is legally solid.
Need help drafting your GST appeal or responding to SPL-07?
👉 Talk to our experts at Efiletax.in and get professional assistance in filing APL-01 with confidence.
Summary
GST Portal now allows appeals (APL-01) against SPL-07 waiver rejection orders from July 16, 2025, as per GSTN Advisory No. 615.Know the process, legal angle, and expert tips before submitting.