GST appeal limitation cannot be bypassed except in truly exceptional cases under writ jurisdiction.

An appeal under the Central Goods and Services Tax Act, 2017 cannot be entertained beyond the statutory period prescribed in Section 107, and the Appellate Authority lacks power to admit a time-barred appeal. The High Court may, in truly exceptional and extraordinary cases, use Article 226 to grant relief despite delay, but only where the explanation for delay is convincingly established. On the facts described, a delay of 317 days was not sufficiently explained, the medical material did not support incapacity to act within time, and no exceptional circumstance was shown. The challenge to the limitation-based rejection therefore failed and the impugned orders remained undisturbed.

---

---

Issues: Whether the delay in filing the GST appeal could be condoned in exercise of writ jurisdiction on the basis of exceptional circumstances, notwithstanding the statutory limitation under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: The appeal before the Appellate Authority had been rejected as time-barred. The legal position had already been settled that the Appellate Authority cannot entertain an appeal filed beyond the prescribed period under Section 107 of the Central Goods and Services Tax Act, 2017. However, in an appropriate case of exceptional and extraordinary nature, the High Court may exercise its extraordinary equitable jurisdiction under Article 226 of the Constitution of India to condone the delay and direct consideration on merits. On the facts pleaded, the explanation for the delay of 317 days was found insufficient. The medical material did not support the claim that the petitioner was prevented from acting within time, and the cause shown did not establish exceptional circumstances.

Conclusion: The delay was not liable to be condoned and the writ petition failed.

Final Conclusion: The challenge to the limitation-based rejection did not succeed, and the impugned orders were left undisturbed.

Ratio Decidendi: An appeal under Section 107 of the Central Goods and Services Tax Act, 2017 cannot be entertained beyond the statutory period, and delay beyond that period may be condoned under Article 226 of the Constitution of India only in truly exceptional and extraordinary circumstances.

---