Appellate Authority Ordered to Verify Technical Glitch, Accept Payments as Valid Pre-Deposits, and Proceed with Appeals.

The writ petitions were allowed, and the Appellate Authority's orders were set aside. The matters were remanded to the Appellate Authority with instructions to verify the technical glitch claimed by the petitioners and to accept payments made under DRC-03 as valid pre-deposits under APL-01. The Appellate Authority must proceed with the appeals accordingly. No costs were awarded, and all pending applications were closed.

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Issues:
1. Rejection of appeals due to late filing and non-payment of required pre-deposit under Section 107 of the Central Goods and Services Act, 2017.
2. Dispute regarding the payment made under a different head (DRC-03) instead of the required head (APL-01) due to technical glitch.
3. Appellate Authority's refusal to accept the payment under DRC-03 as a valid pre-deposit under APL-01.

Analysis:
The petitioners, registered dealers operating oil mills, challenged notices of demand raising additional tax claims by the Assessing Officers. Their appeals to the Appellate Authority were rejected for being filed late and for not making the mandatory 10% pre-deposit under Section 107 of the Central Goods and Services Act, 2017. The Hon'ble Division Bench remanded the matters back to the Appellate Authority for reconsideration of the delay condonation and pre-deposit issues.

The petitioners faced a hurdle in making the pre-deposit under APL-01 due to a technical glitch, leading them to make the payment under a different head, DRC-03. Despite the Appellate Authority accepting the delay condonation, it refused to acknowledge the payment under DRC-03 as a valid pre-deposit under APL-01, prompting the petitioners to file new writ petitions challenging these rejections.

The petitioners argued that their payment under DRC-03 should be considered valid as it was due to the technical issue preventing payment under APL-01. They contended that the Commercial Tax Department received the pre-deposit, fulfilling the substantive requirement of the Act. Conversely, the Government Pleader for Commercial Tax maintained that the Act mandates a specific method of pre-deposit, and any deviation would not meet the statutory requirements, supporting the Appellate Authority's decision.

The Hon'ble Division Bench's previous directive required the Appellate Authority to investigate if there was a technical issue preventing the proper pre-deposit and to accept the payment under DRC-03 as payment under APL-01 if satisfied. However, the Appellate Authority failed to adhere to this directive, leading to non-compliance with the court's instructions.

Consequently, the writ petitions were allowed, setting aside the Appellate Authority's orders and remanding the matters back to the Appellate Authority. The Appellate Authority was instructed to ascertain the technical glitch faced by the petitioners, accept the payments made under DRC-03 as valid pre-deposits under APL-01, and proceed with the appeals accordingly. No costs were awarded, and pending applications were closed as a result of this decision.

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