Limitation for GST appeal ran from date of knowledge, and Section 14 exclusion was recognised for filing the statutory appeal.

A GST registration cancellation challenge was addressed on limitation grounds, with the Court treating limitation for the statutory appeal as running from the date the petitioner claimed to have first learned of the cancellation order, since that assertion was not disputed by the State. On that footing, the petitioner was found to have had time remaining to file the appeal when the writ petition was filed, and the benefit of Section 14 of the Limitation Act, 1963 was also recognised. The petitioner was therefore permitted to file the appeal within three weeks, and if filed, it was to be heard on merits without any objection as to limitation.

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Issues: Whether the petitioner could be permitted to pursue a statutory appeal against cancellation of GST registration without objection on limitation, and whether the petitioner was entitled to the benefit of exclusion of time under Section 14 of the Limitation Act, 1963.

Analysis: The petitioner asserted that the cancellation order had come to its knowledge only on 04.11.2024, and the State filed no counter affidavit to dispute that assertion. On that basis, the limitation for filing the appeal was treated as commencing from 04.11.2024, and it was further held that the petitioner had a surviving period to file the appeal when the writ petition was instituted on 16.12.2024. The petitioner was also held entitled to the benefit of Section 14 of the Limitation Act, 1963.

Conclusion: The petitioner was permitted to file the statutory appeal within three weeks, and if so filed, it was to be entertained on merits without objection as to limitation.

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