Applications Under the GST Waiver Scheme

Challenges in Filing SPL 01/SPL 02 Applications Under the GST Waiver Scheme

The GST Waiver Scheme has been introduced to provide relief to taxpayers, but several challenges have emerged in the filing process for SPL 01 and SPL 02 applications. Many taxpayers have reported technical and procedural difficulties, leading to delays and complications. This blog outlines the key issues faced, solutions available, and important deadlines to ensure a smooth filing process.

Common Issues Faced by Taxpayers

1. Order Number Not Available in Dropdown (SPL 02)

While filing SPL 02, some taxpayers are unable to find the relevant order number in the dropdown list. This prevents them from selecting the appropriate order and proceeding with the application.

2. Auto-Population Issues in SPL 02

• After selecting a specific order, taxpayers have observed that the order details do not automatically populate in SPL 02. This forces them to enter the information manually, increasing the risk of errors.

• Payment details are also missing in Table 4 of SPL 02, which complicates the submission process.

3. Payment Issues Linked to SPL 02

• Taxpayers are experiencing difficulties in making payments through the "Payment Towards Demand" functionality after submitting SPL 02.

• Additionally, payments made via DRC-03 cannot be adjusted against the same demand order using Form DRC-03A, causing further inconvenience.

4. Challenges in Withdrawing Appeal Applications (APL 01)

Many taxpayers who had earlier filed an appeal before the First Appellate Authority (APL 01) against a particular order are unable to withdraw their applications, leading to additional procedural roadblocks.

The GSTN team is actively addressing these issues and working towards their resolution. Taxpayers are encouraged to raise grievance tickets if they continue to face difficulties.

Clarification on Filing Deadlines

There is a common misconception that the last date to file waiver applications is March 31, 2025. However, this is incorrect.

• Deadline for Filing SPL 01 and SPL 02 Applications: As per Rule 164(6) of the CGST Rules, 2017, taxpayers must submit their waiver applications within three months from the notified date. This means that the final deadline for submission is June 30, 2025.

• Deadline for Payment Under the Waiver Scheme: According to Notification 21/2024-CT dated October 8, 2024, the last date to make the required tax payment under the scheme is March 31, 2025. Taxpayers must utilize the "Payment Towards Demand" functionality on the GST portal to complete their payments before this date.

Alternative Payment Method for Functional Issues

If taxpayers encounter problems with the "Payment Towards Demand" functionality, they can use the following alternative method:

1. Make a Voluntary Payment Using Form DRC-03

   • Select the category ‘Others’ while making the payment.

2. Link the Payment Using Form DRC-03A

   • After completing the payment through DRC-03, taxpayers must submit Form DRC-03A to associate the payment with the relevant demand order.

How to Verify Payment Details in SPL 02

If payment details are not auto-populated in Table 4 of SPL 02, taxpayers should manually verify their payment records using the Electronic Liability Ledger on the GST portal. The steps are as follows:

• Navigate to Login → Services → Ledgers → Electronic Liability Register

• Check for payment details and confirm the transaction

• Once verified, proceed with the waiver application submission

Final Recommendations for Taxpayers

• Complete Payment by March 31, 2025: Any delay beyond this date may lead to non-compliance under the waiver scheme.

• File SPL 01/SPL 02 Applications by June 30, 2025: Missing this deadline could result in the loss of waiver benefits.

• Raise Grievance Tickets for Technical Issues: Prompt reporting of issues will help expedite resolutions by the GSTN team.

For further assistance, taxpayers can consult GST professionals to ensure smooth compliance and avoid any unnecessary legal or financial consequences.

Stay proactive and compliant—act now to avoid last-minute challenges in filing your waiver applications!

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