Appeal limitation after rectification follows dismissal of the rectification application, not the original assessment order date.

Where a rectification application is filed against an assessment order under the CGST Act, the limitation period for an appeal against the original assessment runs from the date the rectification application is disposed of, not from the date of the original assessment order. The text states that rectification may alter the original order or be rejected, and that an appeal should not be treated as time-barred merely because the original assessment pre-dates the rectification decision. This approach preserves the effectiveness of appellate remedy when rectification proceedings are pursued before appeal.

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Issues: Whether, for challenging the original assessment order, the period of limitation for appeal runs from the date of the original assessment order or from the date of disposal of the rectification application.

Analysis: Under Section 161 of the Central Goods and Services Tax Act, 2017, a rectification application may result in the original order being modified or remain rejected. Where rectification is sought against an assessment order, the appellate challenge to that assessment cannot be treated as time-barred by reckoning limitation only from the date of the original assessment when the rectification application has been pursued and decided later.

Conclusion: The limitation period for filing the appeal against the original assessment order shall be computed from the date on which the rectification application was dismissed, not from the date of the original assessment order.

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