Condonation of delay where documented electronic filing failure constituted sufficient cause, leading to admission of the late appeal.

The proviso to Section 100(2) of the Central Goods and Services Tax Act, 2017 permits admission of an appeal presented within a further period not exceeding thirty days where the appellant was prevented by sufficient cause; documented repeated portal errors, screenshots and a helpdesk ticket were accepted as a preventing cause and sufficient evidence of inability to file online, and consequently a 28 day delay beyond the original period was condoned and the appeal admitted for consideration on merits.

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Issues: Whether the delay of 28 days in filing the appeal against Advance Ruling No. 42/AAR/2025 dated 08.10.2025 can be condoned under the proviso to Section 100(2) of the Central Goods and Services Tax Act, 2017.

Analysis: The Appellate Authority considered the appellant's evidence that the Advance Ruling was received in October 2025 and that repeated attempts to file the appeal online were unsuccessful due to a recurring portal error, supported by screenshots and a helpdesk ticket. The appeal was filed physically on 10.12.2025, resulting in a delay of 28 days beyond the normal 30-day period. The proviso to Section 100(2) allows the Appellate Authority to admit an appeal presented within a further period not exceeding thirty days if satisfied that the appellant was prevented by sufficient cause from presenting the appeal within the original period. The Authority found the documentary evidence of technical failure and helpdesk interaction credible and sufficient to constitute a preventing cause within the meaning of the proviso.

Conclusion: The delay of 28 days in filing the appeal is condoned under the proviso to Section 100(2) of the Central Goods and Services Tax Act, 2017, and the appeal is admitted for consideration on merits.

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