GST appeal limitation under Section 107 excludes Section 5 condonation beyond the statutory outer limit.

Section 107 of the Central Goods and Services Tax Act, 2017 is treated as a self-contained limitation scheme, so the appellate forum can extend time only within the statutory limit in Section 107(4). The text states that there is no express or implied basis for applying Section 5 of the Limitation Act, 1963 to condone delay beyond the outer permissible period. On that reasoning, an appeal filed after the statutory deadline remains time-barred, the writ challenge fails, and the appellate order and cancellation of registration are left undisturbed.

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Issues: Whether the delay in filing the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017 could be condoned by applying Section 5 of the Limitation Act, 1963.

Analysis: Section 107 of the Central Goods and Services Tax Act, 2017 was treated as a special limitation provision forming part of a self-contained fiscal code. The appellate forum could extend time only to the extent permitted by Section 107(4), and there was no statutory basis for invoking Section 5 of the Limitation Act, 1963. The appeal had been filed beyond the outer permissible period, and the absence of an express or implied incorporation of the Limitation Act excluded condonation beyond that limit.

Conclusion: The delay was not condonable under Section 5 of the Limitation Act, 1963, and the challenge to the appellate order failed.

Final Conclusion: The writ petition was rejected as having no merit, leaving the impugned appellate order and cancellation of registration undisturbed.

Ratio Decidendi: Where the GST appellate provision prescribes a complete and self-contained limitation scheme without expressly extending the benefit of the Limitation Act, general condonation provisions do not apply beyond the statutory outer limit.

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