GST appeal limitation runs from rejection of rectification application, not from the original assessment order.

A rectification application under Section 161 of the CGST Act is a statutory post-assessment remedy that can affect the finality of the assessment order for appellate purposes. If rectification is allowed, the resulting order merges with the original assessment; if it is rejected, the rejection order becomes the relevant subsequent order for computing limitation. Accordingly, the limitation period for filing an appeal against the original assessment order runs from the date of rejection of the rectification application, not from the date of the original assessment order.

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Issues: Whether, where a rectification application under Section 161 of the Central Goods and Services Tax Act, 2017 is filed against an assessment order and is subsequently rejected, the period of limitation for filing an appeal against the original assessment order begins from the date of the original order or from the date of disposal of the rectification application.

Analysis: Rectification under Section 161 is a statutory post-assessment remedy, and its disposal may either alter the original order or leave it untouched. If rectification is allowed, the resulting order merges with the original order; if it is rejected, the rejection order becomes the relevant subsequent order for computing limitation. In such a situation, the time to challenge the assessment order cannot be treated as running from the date of the original assessment alone, because the rectification proceedings are part of the same statutory process and directly affect the finality of the assessment order for appellate purposes.

Conclusion: The limitation period for filing an appeal against the original assessment order starts from the date on which the rectification application is rejected, not from the date of the original assessment order.

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