GST appeal filing rules: manual presentation after portal failure could not defeat the statutory right of appeal.

An appeal under the GST regime could not be rejected solely because it was presented manually after an attempted electronic filing failed due to a technical glitch. Rule 108(1) allows electronic filing or filing otherwise as notified by the Commissioner, and the absence of a notification authorising manual filing did not justify denying the statutory right of appeal where the portal itself prevented upload. The principle that substantial justice should prevail over technical objections supported acceptance of the appeal, and the rejection of the manually filed appeal was held unjustified.

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Issues: Whether an appeal under the GST regime could be rejected merely because it was presented manually, when the appellant had attempted electronic filing but was prevented by a technical glitch and no notification had yet been issued for filing otherwise than electronically.

Analysis: Rule 108(1) permits an appeal to be filed electronically or otherwise as notified by the Commissioner. The record showed an attempted electronic upload which was not processed by the portal because of a technical difficulty, followed by manual presentation of the appeal. In these circumstances, the appellant could not be denied the statutory right of appeal merely for want of a notification authorising manual filing. The principle that substantial justice must prevail over technical objections supported acceptance of the appeal.

Conclusion: The rejection of the manually filed appeal was unjustified and the appellant's challenge succeeded.

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