Manual appeal filed within limitation cannot be rejected for portal filing issues; matter directed to be heard on merits.

A manually filed appeal lodged within the limitation period after payment of the admitted tax and pre-deposit could not be rejected merely because the online filing was not accepted on limitation grounds. The Madras HC held that the appellant should not be denied an opportunity to pursue the statutory appeal when the manual filing was already within time. The rejection order was set aside, and the appellate authority was directed to take the manually filed appeal on record and decide it on merits in accordance with law.

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Issues: Whether the rejection of the manually filed appeal, on the ground that it had to be filed only through the online portal and was hit by limitation, was liable to be set aside and the appeal taken on record for decision on merits.

Analysis: The appeal had been filed manually within the period of limitation after payment of the admitted tax and pre-deposit. The subsequent attempt to file the appeal through the online portal was not accepted on limitation grounds, though the manual filing was already within time. In these circumstances, the Court found that the petitioner should not be denied an opportunity to pursue the appeal and that the dispute ought to be examined by the appellate authority on merits after affording a sufficient opportunity.

Conclusion: The rejection order was set aside and the appellate authority was directed to take the manually filed appeal on record and decide it on merits in accordance with law.

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