Statutory GST appeal limits cannot be extended beyond the prescribed outer period, while registration may be restored on dues payment.

The GST appeal provision prescribes a three-month filing period with only a further one-month condonable period, and delay beyond that statutory outer limit cannot be extended by the appellate authority. The text also notes that no timely revocation application or appeal had been filed. On registration, cancellation was interfered with because the defaulting taxpayer's dues were not opposed by the State being paid, and restoration was made conditional on payment of tax dues, interest, late fee, penalty, and compliance with required formalities.

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Issues: (i) Whether delay beyond the statutory limit under the goods and services tax appeal provision could be condoned; (ii) whether cancellation of GST registration should be set aside and registration revived subject to payment of dues.

Issue (i): Whether delay beyond the statutory limit under the goods and services tax appeal provision could be condoned.

Analysis: The appeal provision prescribed a filing period of three months with a further condonable period of one month, and the outer limit fixed by the statute could not be extended by the appellate authority. The judgment also noted that no application for revocation or appeal within the prescribed time had been filed.

Conclusion: The delay beyond the statutory condonable period could not be extended.

Issue (ii): Whether cancellation of GST registration should be set aside and registration revived subject to payment of dues.

Analysis: The petitioner had defaulted in payment of tax, but the State did not oppose relief subject to payment of tax dues, interest, late fee, and penalty. In these circumstances, the cancellation order was interfered with and directions were issued to restore the registration on compliance with the monetary obligations and related formalities.

Conclusion: The cancellation order was set aside and the registration was directed to be revived subject to payment of the outstanding dues and compliance requirements.

Final Conclusion: The petition was allowed, with restoration of GST registration made conditional upon payment of the statutory dues and completion of the required formalities.

Ratio Decidendi: Where the goods and services tax statute prescribes a fixed outer limit for appeal, the authority cannot condone delay beyond that limit, and cancellation of registration may be interfered with and restored where the dues are directed to be paid and compliance is secured.

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