GST appellate limitation strictly confines condonation, leaving no jurisdiction to admit appeals filed beyond the statutory extension period.

Section 107 of the Central Goods and Services Tax Act, 2017 establishes a self-contained appellate limitation regime: an appeal must be filed within three months, with condonation available only for a further one-month period on sufficient cause. Section 5 of the Limitation Act, 1963 is excluded by necessary implication under Section 29(2), as the statutory scheme demonstrates legislative intent to confine the Appellate Authority's condonation power to that expressly prescribed period. Accordingly, the Appellate Authority lacks jurisdiction to entertain appeals filed beyond the limitation periods under Section 107(1) and Section 107(4).

---

---

Issues: Whether an appeal under Section 107 of the Central Goods and Services Tax Act, 2017 can be entertained beyond the prescribed three-month period and the further condonable period of one month by applying Section 5 of the Limitation Act, 1963.

Analysis: Section 107 creates a specific appellate regime, prescribing three months for appeal and permitting condonation only for a further period of one month upon sufficient cause. The fiscal statute is a self-contained code intended to ensure certainty, finality and expeditious resolution of tax disputes. Under Section 29(2) of the Limitation Act, 1963, exclusion of Section 5 may arise by necessary implication from the statutory scheme; an express exclusion is not indispensable. The scheme of Section 107 manifests legislative intent to restrict the Appellate Authority's condonation power to the expressly stipulated additional period. The ruling concerning appeals under the beneficial land-acquisition legislation was distinguished as dependent on its materially different statutory object and framework.

Conclusion: Section 5 of the Limitation Act, 1963 is excluded by necessary implication, and the Appellate Authority has no jurisdiction to entertain an appeal filed beyond the periods prescribed by Section 107(1) and Section 107(4) of the Central Goods and Services Tax Act, 2017.

---