FORM GST SPL-08 - Undertaking to restore the original appeal after waiver denial is upheld
The appellate authority upholds SPL-07 and the applicant seeks restoration of the original withdrawn demand appeal.
Responsible actor: The applicant gives the prescribed no-further-appeal undertaking. Provision: Rule 164(15)(b)(ii).
Official source and completed example
Download official blank source extract PDF Download completed fictional sample PDF
The sample is a flowed model of the prescribed fields and selected paragraphs, not an official issued PDF. Names, references and facts are fictional. It contains no signature, stamp, DSC or simulated approval.
Historical worked applications filed in June 2025 for FY 2019–20 section 73 demands. Checked 21 October 2026 against rule 164 as amended 27 March 2025. Ordinary tax-payment deadline 31 March 2025 and ordinary application deadline 30 June 2025 have passed. For the separate section 75(2) redetermination route, notification 21/2024 measures the six-month tax-payment period from issue of the redetermination order; rule 164(6) measures the six-month application period from communication. These illustrations do not represent a new general waiver window.
Worked facts and completed entries
Independent branch C has a FY 2019–20 section 73 demand ILLUSTRATION-ORDER-C dated 15 June 2024, tax INR 1 lakh and stated assessed interest/penalty INR 30,000/20,000. Only INR 90,000 tax was paid by 31 March 2025, including the original appeal’s INR 10,000 pre-deposit. The final INR 10,000 was paid on 5 April. Original appeal ILLUSTRATION-APL-C dated 15 July 2024 was withdrawn 10 June 2025; SPL-02-C was filed 20 June. This is the ordinary deadline class, with no section 75(2) redetermination or statutory extension. Aster appeals SPL-07-C on 30 August 2025. APL-04 ILLUSTRATION-APL04-WAIVER-C dated 10 October confirms the waiver was rightly denied. On 15 October, five days later, Aster gives this undertaking and requests restoration of its original demand appeal. The undertaking does not reverse the waiver denial or grant any interest/penalty exemption.
Date/reference and fields 1–7
| Date / reference | 15 October 2025 / ILLUSTRATION-SPL08-C-2025 |
|---|---|
| 1. Legal name | Aster Learning Supplies Private Limited (fictional) |
| 2. Address | 12 Learning Park, Bengaluru, Karnataka 560001 (fictional) |
| 3. GSTIN | 29AABCA0000A1ZT |
| 4. SPL-02 reference / date | ILLUSTRATION-SPL02-C-2025 / 20 June 2025 |
| 5. SPL-07 reference / date | ILLUSTRATION-SPL07-C-2025 / 15 August 2025 |
| 6. APL-04 against SPL-07 / date | ILLUSTRATION-APL04-WAIVER-C / 10 October 2025 |
| 7. Original withdrawn demand appeal / date | ILLUSTRATION-APL-C / 15 July 2024; withdrawn 10 June 2025 |
Prescribed undertaking and prayer
I, Meera Rao, authorised director of the fictional applicant, undertake that no appeal has been filed and none is intended against APL-04 ILLUSTRATION-APL04-WAIVER-C dated 10 October 2025, which upheld the section 128A waiver rejection. I accordingly request restoration of original appeal ILLUSTRATION-APL-C dated 15 July 2024 against ILLUSTRATION-ORDER-C. I do not seek restoration of the waiver benefit through this undertaking.
Verification and applicant execution
| Verifier | Meera Rao, authorised director of the fictional applicant |
|---|---|
| Declaration | The stated information is true to the assumed facts and nothing material is concealed; incorrect declarations can invalidate the benefit |
| Place / date | Bengaluru / 15 October 2025 |
| Signature / DSC / EVC | Not executed |
| Email / mobile | aster@example.test / 0000000000 (fictional, non-operational) |
Time and consequence
| Elapsed after APL-04 issue | 5 days; within the prescribed three months from issue date |
|---|---|
| Restored matter | Original demand appeal on its proper scope; waiver denial remains undisturbed by this undertaking |
| Tax refund / waiver from SPL-08 | None assumed; actual appellate and portal records determine restoration |
How this form moves the matter forward
- Match the upheld waiver rejection and its APL-04 to the actual withdrawn original appeal.
- File the prescribed undertaking within three months from APL-04 issue date, accurately declaring no filed/intended further appeal against that decision.
- Track restoration of the original appeal; the undertaking itself is not a waiver, refund or merits decision.
Evidence supporting these entries
- SPL-02, SPL-07 and waiver-appeal APL-04
- Original demand appeal and withdrawal record
- Filed undertaking and actual restoration status
Additional primary authority: Notification 21/2024-Central Tax, 8 October 2024, table: ordinary payment 31 March 2025; qualifying section 75(2) redetermination six months from issue.
Additional primary authority: Notification11/2025-Central Tax,27 March 2025, paragraph 2: covered-period tax in mixed orders; partial appeal discontinuance; no refund of previously discharged amounts.
Additional primary authority: Circular238/32/2024,15 October 2024, paragraphs 3.1–3.4: forms, payment mapping, officer/appellate roles, restoration; historical mixed-period statements superseded by March 2025 amendment.
Additional primary authority: Circular248/05/2025,27 March 2025, table items 1–2: pre-November 2024 GSTR-3B payments and amended mixed-period treatment.
Period and legal consequences
Historical worked applications filed in June 2025 for FY 2019–20 section 73 demands. Checked 21 October 2026 against rule 164 as amended 27 March 2025. Ordinary tax-payment deadline 31 March 2025 and ordinary application deadline 30 June 2025 have passed. For the separate section 75(2) redetermination route, notification 21/2024 measures the six-month tax-payment period from issue of the redetermination order; rule 164(6) measures the six-month application period from communication. These illustrations do not represent a new general waiver window.
Primary source and exact locator
Official notified form source: Notification20/2024-Central Tax,8 October 2024, FORM GST SPL-08, PDF pages 32–32.
CGST Act and government-hosted Act and Rules compilation - Rule 164(15)(b)(ii). Source and example revision: 21 October 2026.
Questions answered by this example
Who prepares or issues this form?
The applicant gives the prescribed no-further-appeal undertaking. The appellate authority upholds SPL-07 and the applicant seeks restoration of the original withdrawn demand appeal.
Can this sample be filed or treated as an issued document?
No. It is a completed fictional teaching example. Use the notified form and the authenticated portal/proceeding record for an actual matter. The example contains no executed signature or official approval.
What must reconcile before the next step?
SPL-02, SPL-07 and waiver-appeal APL-04; Original demand appeal and withdrawal record; Filed undertaking and actual restoration status.