This instruction clarifies the application of Section 128A of the CGST Act, which provides waiver of interest or penalty relating to demands under Section 73 for FYs 2017–18 to 2019–20. It clarifies that taxpayers are eligible for the benefit even where the department has filed or proposes to file an appeal only on issues of interest calculation or penalty imposition, provided tax has been fully paid. The Board emphasises that technical pendency of departmental appeals should not defeat the intent of litigation reduction. Proper officers are directed to withdraw such appeals or accept orders at review stage where conditions of Section 128A are fulfilled. The instruction reinforces the objective of reducing legacy GST disputes