GST appeal limitation starts on communication by email, and portal upload does not extend time or revive a barred challenge.

For an appeal under GST section 107, limitation begins when the assessment order is communicated to the assessee, and an email communication satisfies that requirement. The later uploading of the same order on the GST portal does not postpone the statutory start of time. Rule 108 governs the manner of filing an appeal but cannot alter the limitation period fixed by the statute. Once the prescribed appeal period, including the limited condonable extension, expires, writ jurisdiction cannot be used to revive the lost remedy or bypass the mandatory limitation scheme. The time-barred challenge was therefore not maintainable.

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Issues: Whether the period for filing an appeal under section 107 began from the email communication of the assessment order or from its later upload on the GST portal, and whether writ jurisdiction could be invoked after the appeal had become time-barred.

Analysis: The assessment order under section 62 was communicated by email on the date of the order. Section 107(1) requires an appeal within three months from the date on which the decision or order is communicated, and section 107(4) permits only a further one-month extension on sufficient cause. Rule 108 regulates the mode and filing mechanics of the appeal, but it does not alter the statutory point of commencement of limitation. The later uploading of the order on the GST portal did not postpone communication for limitation purposes. The Court also held that once the statutory appeal was lost by expiry of the prescribed period, writ jurisdiction could not be used to bypass the mandatory limitation scheme.

Conclusion: The appeal period ran from the email communication of the order, not from its portal upload, and the belated appeal was rightly not entertained; the writ challenge was not maintainable against the time-barred order.

Final Conclusion: The statutory limitation under the GST law was held to be strict and binding, and the petitioner was left without relief against the assessment order.

Ratio Decidendi: For purposes of section 107, limitation commences on communication of the order to the assessee, and the High Court cannot invoke Article 226 to revive a remedy lost by expiry of the statutory appeal period.

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