Limitation: appeal beyond the expressly limited further period cannot be condoned, resulting in dismissal for want of temporal jurisdiction.

The appeal raises whether an appeal from an AAR order is barred by limitation and whether the appellate authority may extend the statutory further period beyond that expressly permitted. The authority applied the statutory scheme under section 100(2), held that the proviso allows only a single further period not exceeding thirty days for sufficient cause, and found the appellant's portal confusion immaterial in view of procedural rules allowing manual filing; precedents confirm tribunals cannot exceed an expressly limited extension. Outcome: the appeal was held time-barred and cannot be entertained on merits for want of temporal jurisdiction to condone further delay.

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Issues: Whether the appeal against the Odisha AAR order is barred by limitation and whether the Appellate Authority for Advance Ruling can condone the delay beyond the further period of thirty days permitted by proviso to section 100(2) of the Central Goods and Services Tax Act, 2017.

Analysis: The appeal was filed 250 days after communication of the AAR order. Section 100(2) of the Central Goods and Services Tax Act, 2017 provides a normal period of thirty days from communication and empowers the appellate authority to allow, for sufficient cause, a further period not exceeding thirty days. Rule 107A of the Central Goods and Services Tax Rules, 2017 permits manual filing where electronic filing references exist, making the appellant's stated confusion about portal upload immaterial to the statutory timelines. Precedents cited confirm that tribunals and statutory appellate authorities created by statute cannot extend the expressly limited further period beyond thirty days where the statute so prescribes. The appeal therefore falls outside the temporal jurisdiction conferred by the proviso to section 100(2) and cannot be entertained on merits.

Conclusion: The appeal is time-barred and the Appellate Authority is not empowered to condone the delay beyond the further period of thirty days; accordingly the appeal is dismissed on the ground of limitation without considering merits.

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