Valid service on authorised advocate starts appeal limitation under the U.P. GST Act; delayed challenge fails as time-barred.

Service of an order on an advocate authorised to appear for the taxable person constitutes valid communication under the U.P. GST Act, and the appeal period under section 107(1) runs from that date. On the admitted facts, the order was communicated to the petitioner's advocate on the day it was issued, so limitation expired within three months. A later application for a certified copy did not explain when the petitioner first became aware of the order, and the delay petition was found unsatisfactory. The appeal was therefore time-barred and the challenge to its rejection failed.

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Issues: Whether the appeal was barred by limitation where the order was served on the petitioner's advocate under the service provisions of the U.P. GST Act.

Analysis: The appeal period under section 107(1) of the U.P. GST Act runs from the date on which the decision or order is communicated. Section 169 permits service of an order on an advocate authorised to appear for the taxable person, and such service is treated as valid service. On the admitted facts, the order dated 28.03.2018 was communicated to the petitioner's advocate on the same day, so the limitation period expired within three months thereafter. The explanation that a later counsel applied for a certified copy in June 2019 did not show when or how the petitioner first became aware of the order, and the delay petition did not contain a satisfactory explanation for the delay.

Conclusion: The appeal was rightly held to be time-barred and the challenge to the rejection of the appeal failed.

Ratio Decidendi: Where an order under the U.P. GST Act is served on an advocate authorised to appear for the taxable person, service on the advocate constitutes valid communication to the taxable person, and limitation for appeal runs from that date.

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