Limitation for writ challenge remains fatal where the review court finds the petition time-barred even under the alternative statutory scheme.

The review petition failed because the earlier judgment correctly held the writ challenge to be time-barred. The Court rejected the argument that the limitation scheme under the Finance Act, 1994 should apply instead of the Central Goods and Services Tax Act, 2017, finding that the petition was still filed beyond the outer period even on the petitioner's own alternative basis. It further held that the condonable extension cannot be treated as part of the original limitation period. The petitioner was left free to pursue any statutory appellate remedy, if available in law.

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Issues: Whether the review petition disclosed any error in the earlier judgment dismissing the writ petition as time-barred on the ground of limitation for filing an appeal, and whether the petitioner could avoid that result by invoking the limitation scheme under the Finance Act, 1994 instead of the Central Goods and Services Tax Act, 2017.

Analysis: The earlier dismissal rested on the finding that the writ petition had been filed after expiry of the prescribed period for challenge to the order in original. The Court examined the petitioner's contention that the dispute arose from service tax proceedings under the Finance Act, 1994 and not under the Central Goods and Services Tax Act, 2017, but held that even on that basis the writ petition remained beyond time. It noted the date of the order and the date of communication, and found that the petition was filed after the outer period canvassed by the petitioner as well. The further condonable period could not be counted as part of the original limitation period.

Conclusion: No error was found in the earlier judgment on limitation. The review petition failed and was dismissed. The petitioner was left at liberty to pursue the statutory appellate remedy, if permissible in law.

Final Conclusion: The Court reaffirmed that the challenge to the order was barred by limitation and declined review, while leaving the petitioner to seek appropriate relief before the appellate forum in accordance with law.

Ratio Decidendi: A review will not be entertained where the earlier decision rejecting the writ petition as time-barred is shown to be correct even on the petitioner's own alternative statutory framework, and the condonable extension cannot be treated as part of the original limitation period.

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