CGST appeal limitation bars further condonation beyond the statutory one-month extension under special law.

Under the CGST appeal framework, the appellate authority can condone delay only within the additional one-month period expressly allowed by Section 107(4). Section 29(2) of the Limitation Act does not enlarge that power where the special statute forms a complete code and fixes an outer limit for filing and condonation. The absence of an express exclusion clause does not permit further recourse to Sections 4 to 24 of the Limitation Act when the CGST Act itself occupies the field. Further condonation beyond the statutory limit was therefore unavailable.

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Issues: Whether the appellate authority under the CGST regime had power to condone delay beyond the additional period expressly provided in the statute, and whether Section 29(2) of the Limitation Act, 1963 enabled further condonation.

Analysis: Section 107(1) of the CGST Act prescribes a three-month period for filing an appeal, while Section 107(4) permits condonation only for a further period of one month on sufficient cause being shown. Applying Section 29(2) of the Limitation Act, the availability of Sections 4 to 24 depends on whether they are expressly excluded by the special law. The statutory scheme, read as a complete code, manifested legislative intent to provide a fixed outer limit for appeal and condonation. The absence of an express exclusion clause did not permit resort to the Limitation Act where the special enactment itself occupied the field and limited condonation. The principle was reinforced by the statutory structure governing appeals in the CGST Act and by the authorities relied upon on special limitation regimes.

Conclusion: The appellate authority had no power to entertain the appeal beyond the period of condonation specifically allowed by Section 107(4) of the CGST Act, and the plea for further condonation under the Limitation Act was rejected.

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