Statutory appeal allowed to challenge final assessment orders within four weeks, subject to pending validity adjudication.

Petitioner sought permission to file a statutory appeal against final assessment orders while the legality of Notifications extending time under Section 73(10) of the GST laws remained pending before higher adjudication. The court confined relief to procedural permission: the petitioner may prefer an appropriate statutory appeal to the Appellate Authority within four weeks, enabling appellate review of the assessment orders without prejudicing the ultimate determination on the validity and legality of the challenged Notifications. The appellate authority's decision is subject to this Court's final adjudication on the Notifications' validity.

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Issues: Whether the petitioner may be permitted to prefer an appropriate statutory appeal before the Appellate Authority to challenge the final assessment orders dated 23-07-2024 and 08-08-2024 notwithstanding that the legality and validity of the Notifications extending time under Section 73(10) of the CGST Act, 2017 and RGST Act, 2017 are pending adjudication before this Court.

Analysis: The petitions sought substantive adjudication on the legality and validity of specified Central and State Notifications extending the time limit under Section 73(10) of the Central Goods and Services Tax Act, 2017 and the Rajasthan Goods and Services Tax Act, 2017. The High Court had not finally adjudicated the assessment challenges and had noted that related issues were pending consideration by this Court. The petitioner requested permission to prefer an appropriate statutory appeal against the final assessment orders; analogous relief had been granted in earlier similar matters by permitting assessees to file statutory appeals within a stipulated timeframe. Having regard to the pendency before this Court of the challenge to the Notifications, the Court limited its order to granting procedural relief to enable the petitioner to pursue the statutory appellate remedy in relation to the assessment orders, without prejudicing this Court's ultimate adjudication on the legality and validity of the Notifications.

Conclusion: The petitioner is permitted to prefer a statutory appeal before the Appellate Authority against the final assessment orders dated 23-07-2024 and 08-08-2024 within four weeks. The appellate authority's decision shall be subject to this Court's ultimate adjudication on the validity and legality of the Notifications.

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