Extraordinary writ jurisdiction cannot bypass an expired statutory GST appeal limitation period to challenge an assessment order.

Expiry of the limitation period for a statutory GST appeal does not by itself justify invoking extraordinary writ jurisdiction under Article 226 to challenge an assessment order. Where the statutory appellate remedy was available but became time-barred, and the rectification application was also apparently delayed, the writ remedy cannot be used merely to overcome the lapse of the appeal period. The article notes that the writ challenge was not maintainable on this basis, and the issue was decided against the assessee.

---

---

Issues: Whether extraordinary writ jurisdiction could be invoked to challenge a GST assessment order where the statutory appeal had become time-barred and a rectification application was pending.

Analysis: The statutory appellate remedy was available but had become barred by limitation. The pending rectification application also appeared to be time-barred. Expiry of the period for pursuing the statutory appeal does not, by itself, justify exercise of extraordinary jurisdiction under Article 226 of the Constitution of India.

Conclusion: The writ petition challenging the assessment order was not maintainable in extraordinary jurisdiction merely because the statutory appeal was time-barred; the issue was decided against the assessee.

Ratio Decidendi: Lapse of the limitation period for a statutory appeal is not a ground for invoking extraordinary writ jurisdiction to obtain relief against a fiscal assessment order.

---