Statutory limits on GST appeal delay prevent excess condonation, while implemented registration restoration renders departmental challenge non-maintainable.
Case-Laws
GST
Statutory appellate power to condone delay in GST registration-cancellation appeals ends at the outer limit prescribed by Section 107(4); writ orders granting relief on particular facts do not enlarge that power, and equity or hardship cannot override the limit. Condonation beyond that period is therefore without jurisdiction. Where the Department has implemented an appellate restoration order by reinstating GST registration, its subsequent challenge to that order is barred by its own conduct: reversal would disrupt the restored registration and intervening transactions, with no effective relief available. The departmental appeal is consequently treated as infructuous and not maintainable.
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