Issues: Whether a domestic company that validly exercised the option under section 115BAA in an earlier assessment year was entitled to the concessional tax rate for the subsequent assessment year without filing Form No. 10-IC afresh.

Analysis: Section 115BAA permits a domestic company to opt for the prescribed concessional rate subject to fulfilment of the stipulated conditions. Under section 115BAA(5), the option is to be exercised in the prescribed manner by the specified date and, once exercised, applies to subsequent assessment years; it cannot be withdrawn. Form No. 10-IC is the prescribed mode for initially exercising the option and is not an annual requirement. The option had been validly exercised and accepted in the preceding assessment year, while no breach of conditions under section 115BAA or invalidity of the option was identified for the year in question. The statutory continuity of the option therefore governed the intervening assessment year.

Conclusion: The assessee was entitled to taxation at the concessional rate under section 115BAA for the relevant assessment year, and its tax liability was required to be recomputed accordingly.

Issues: Whether the Revenue's miscellaneous application sought rectification of a mistake apparent from the record or an impermissible review of the Tribunal's earlier order.

Analysis: Section 254(2) of the Income-tax Act, 1961 confines the Tribunal's power to correcting an apparent mistake in its order. It does not authorise reconsideration of facts, reappraisal through further arguments, or review of a concluded decision. The grounds raised by the Revenue sought reconsideration of the earlier jurisdictional finding and did not disclose any apparent mistake capable of rectification.

Conclusion: The application sought an impermissible review and disclosed no mistake apparent from the record.

Issues: Whether the prior appellate order could be rectified under Section 254(2) of the Income-tax Act, 1961 on the ground that an adjournment sought by the assessee was not granted.

Analysis: Rectification under Section 254(2) is confined to an obvious, patent and glaring error apparent from the record; it cannot be invoked to review or revisit the merits of an order through a process requiring arguments or extended reasoning. No material established non-service of hearing notices, and refusal of an adjournment was not an apparent error. The application sought a review of the earlier order rather than correction of a patent mistake.

Conclusion: No mistake apparent from the record existed to justify rectification under Section 254(2) of the Income-tax Act, 1961.

Issues: (i) Whether the First Appellate Authority was justified in condoning delay beyond the maximum period permitted by Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department's appeals were maintainable after it had implemented the impugned orders by restoring registrations; and (iii) Whether the respondents' inability to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded their statutory appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority was justified in condoning delay beyond the maximum period permitted by Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes three months for filing an appeal, while Section 107(4) permits condonation only for a further month upon sufficient cause. Constitutional writ jurisdiction under Article 226 of the Constitution of India may permit relief tailored to exceptional facts, but such relief cannot enlarge the statutory jurisdiction of the First Appellate Authority. The prescribed outer limitation is mandatory, and equity follows the law.

Conclusion: The First Appellate Authority was not justified in condoning delay beyond the statutory outer limit; this issue is decided in favour of the Revenue.

Issue (ii): Whether the Department's appeals were maintainable after it had implemented the impugned orders by restoring registrations.

Analysis: The Department restored the registrations pursuant to the impugned orders, following which the respondents resumed business and their registrations remained active. That implementation materially altered the parties' position, and annulment of the orders would yield no effective relief while unsettling transactions undertaken after restoration. The challenge consequently became academic.

Conclusion: The Department's appeals were not maintainable in the circumstances; this issue is decided in favour of the assessees.

Issue (iii): Whether the respondents' inability to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded their statutory appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: Once the prescribed period had elapsed, the common portal did not permit applications for revocation. The remedy of appeal under Section 107 operates independently, and inability to invoke Rule 23 cannot extinguish the statutory right to challenge cancellation through an appeal.

Conclusion: The respondents were not precluded from pursuing their statutory appeals; this issue is decided in favour of the assessees.

Final Conclusion: The statutory outer limit on the First Appellate Authority's condonation power remains binding, but the Department's completed restoration of registrations precluded an effective challenge to the appellate orders in this batch.

Issues: Whether losses accumulated at the investment-fund level as on 31 March 2019 may be carried forward by the unit holder under the amended pass-through regime.

Analysis: Section 115UB(2A) of the Income-tax Act, 1961 deems eligible non-business losses accumulated by an investment fund as on 31 March 2019 to be losses of the unit holder holding units on that date. The loss is consequently capable of being carried forward by the unit holder for the unexpired statutory period and set off under Chapter VI. The investment fund's statement attributed the loss to the unit holder on a pro-rata basis; factual verification was required regarding the attribution and non-availability of that loss to the fund after 1 April 2019.

Conclusion: The unit holder is entitled to carry forward the attributable accumulated loss under Section 115UB(2A), subject to verification of the relevant facts. The issue is decided in favour of the assessee.

Issues: Whether the disallowance of input tax credit based on alleged fake invoices requires reconsideration of the actual receipt of gold consignments and the applicability of the extended period of limitation.

Outcome: The impugned order was set aside and the matter was returned for fresh consideration upon the petitioner filing a reply to the show-cause notice.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the maximum period prescribed under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could challenge the appellate orders after implementing them by restoring the taxpayers' registrations; and (iii) Whether inability to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded the taxpayers from pursuing an appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay beyond the maximum period prescribed under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation for appeal, while Section 107(4) permits condonation only within the additional period expressly stipulated. The statutory appellate jurisdiction of the First Appellate Authority is confined to those limits. Relief granted by a High Court under Article 226 of the Constitution of India in the exercise of extraordinary jurisdiction cannot enlarge the Authority's statutory power. Equity follows the law and cannot override an express statutory limitation.

Conclusion: No. The First Appellate Authority lacked jurisdiction to condone delay beyond the statutory outer limit; such condonation was coram non judice and ultra vires. This issue was decided in favour of the Revenue.

Issue (ii): Whether the Department could challenge the appellate orders after implementing them by restoring the taxpayers' registrations.

Analysis: The Department had acted upon the appellate orders, restored the registrations, and thereby enabled the taxpayers to conduct business and comply with their obligations. Those material subsequent developments altered the legal and commercial position. The Department could not seek invalidation of orders it had already implemented without addressing the consequences of restoration, and no effective relief could be granted through the proceedings.

Conclusion: No. Having implemented the restoration of registrations, the Department could not obtain relief to unsettle the resulting position. This issue was decided in favour of the taxpayers.

Issue (iii): Whether inability to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded the taxpayers from pursuing an appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: Once the prescribed period had elapsed, the common portal did not permit the taxpayers to file revocation applications under Rule 23. The statutory appeal under Section 107 remained an alternative statutory remedy, and non-use of the revocation process could not extinguish or prejudice the right to challenge cancellation in appeal.

Conclusion: No. The inability to invoke Rule 23 did not bar the taxpayers from pursuing the independent appellate remedy. This issue was decided in favour of the taxpayers.

Final Conclusion: Although the condonation of delay by the First Appellate Authority was legally unsustainable, the Department's prior implementation of the orders and restoration of registrations prevented the taxpayers' restored status from being disturbed in these proceedings.

Ratio Decidendi: A statutory appellate authority cannot condone delay beyond the outer limit fixed by the statute by relying on discretionary relief granted by a constitutional court under Article 226 of the Constitution of India.

Issues: (i) Whether the First Appellate Authority could condone an appeal filed beyond the outer limit in Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could challenge the appellate orders after implementing them by restoring the taxpayers' registrations; and (iii) Whether non-compliance with Rule 23 of the Central Goods and Services Tax Rules, 2017 barred the taxpayers from pursuing appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone an appeal filed beyond the outer limit in Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary period for filing an appeal, and Section 107(4) permits condonation only within the further period expressly stipulated on sufficient cause. A statutory appellate authority is confined to this legislatively prescribed jurisdiction. Directions or relief granted by a High Court under Article 226 of the Constitution of India, in exercise of extraordinary and equitable jurisdiction, cannot enlarge the statutory authority's power to condone delay. Equity follows the law and cannot override an express outer limitation.

Conclusion: The First Appellate Authority lacked jurisdiction to condone delay beyond the maximum period under Section 107(4); such condonation was coram non judice and ultra vires. This issue is in favour of Revenue.

Issue (ii): Whether the Department could challenge the appellate orders after implementing them by restoring the taxpayers' registrations.

Analysis: The Department implemented the appellate orders, restored the registrations, and permitted the taxpayers to resume business and undertake transactions. This subsequent development materially altered the parties' position. Setting aside the orders thereafter could expose the restored registrations and intervening genuine transactions, including related input-tax-credit consequences, to uncertainty, while yielding no effective relief to the Department.

Conclusion: The Department could not obtain effective relief against orders that it had already implemented by restoring the registrations. This issue is in favour of the assessee.

Issue (iii): Whether non-compliance with Rule 23 of the Central Goods and Services Tax Rules, 2017 barred the taxpayers from pursuing appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: The common portal did not permit revocation applications after expiry of the prescribed period. The appellate remedy under Section 107 is independent, and the inability to invoke the revocation mechanism under Rule 23 does not extinguish the statutory right to challenge cancellation through appeal.

Conclusion: Non-compliance with Rule 23 did not bar the taxpayers from pursuing the statutory appellate remedy. This issue is in favour of the assessee.

Final Conclusion: The statutory limitation on the First Appellate Authority's condonation power was affirmed, but the Department's prior implementation of the appellate orders precluded the restored registrations from being unsettled through these proceedings.

Ratio Decidendi: A statutory appellate authority cannot enlarge an expressly capped period for condonation by relying on equitable relief granted under Article 226, and a Department that has implemented an appellate order by restoring registration cannot subsequently obtain ineffective relief to undo that order without addressing the consequences of its own implementation.

Issues: (i) Whether reassessment based on generic group-search reasons, without assessee-specific material for the relevant assessment year, and approval under section 151 was valid; (ii) Whether reassessment could be sustained solely on an unrelated disallowance of employees' welfare contributions when no addition was made on the matters forming the recorded reasons for reopening.

Issue (i): Whether reassessment based on generic group-search reasons, without assessee-specific material for the relevant assessment year, and approval under section 151 was valid.

Analysis: Explanation 2(i) to section 148 deems the Assessing Officer to possess information suggesting escapement of income following a search, but does not dispense with the requirement that such information relate to the particular assessee and the relevant assessment year. The recorded reasons identified only group-level allegations of unaccounted transactions, concealed income and bogus expenses, without identifying any seized document, digital material, escaped income, or assessment-year nexus concerning the assessee. Approval under section 151 on such generic reasons lacked the required application of mind.

Conclusion: The reassessment was invalid because the recorded reasons were vague and lacked assessee-specific particulars, and the approval under section 151 was vitiated by non-application of mind.

Issue (ii): Whether reassessment could be sustained solely on an unrelated disallowance of employees' welfare contributions when no addition was made on the matters forming the recorded reasons for reopening.

Analysis: Section 147 permits assessment of other income only after assessment or reassessment of the income forming the basis of reopening. Under the substituted reassessment framework, the jurisdictional foundation remains the identified information suggesting escapement of income. The reassessment made no addition regarding the search-related allegations recorded as its basis, while the sole disallowance concerning delayed employees' contributions was unrelated to those allegations or to any seized material.

Conclusion: The reassessment could not be sustained solely on the unrelated disallowance when no addition was made on the recorded grounds for reopening.

Final Conclusion: The reassessment lacked jurisdiction on two independent grounds, and the disallowance of employees' welfare contributions could not survive; its merits remained unadjudicated.

Ratio Decidendi: Reassessment jurisdiction must rest on assessee- and year-specific information forming the recorded basis of reopening, and cannot be sustained solely by an unrelated addition where no income is assessed on that recorded basis.

Issues: (i) Whether the First Appellate Authority was justified in condoning the delay in preferring appeals beyond the maximum condonable period under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department's appeals were maintainable after it had implemented the impugned orders by revoking the cancellation of the taxpayers' registrations; and (iii) Whether failure to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded the taxpayers from pursuing an appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority was justified in condoning the delay in preferring appeals beyond the maximum condonable period under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation period for appeal, while Section 107(4) permits condonation only within the further statutorily specified period. A High Court's discretionary relief under Article 226 of the Constitution of India, granted on the facts of a writ proceeding, cannot enlarge the statute-bound jurisdiction of the First Appellate Authority. Equity follows the law and cannot override an express outer limit of limitation.

Conclusion: The question is answered in the negative. The First Appellate Authority lacked jurisdiction to condone delay beyond the statutory outer limit, and such condonation was ultra vires. This issue favours Revenue.

Issue (ii): Whether the Department's appeals were maintainable after it had implemented the impugned orders by revoking the cancellation of the taxpayers' registrations.

Analysis: The Department had implemented the impugned orders, restored the registrations, and thereby enabled the taxpayers to resume business and undertake subsequent transactions. This subsequent development materially altered the position between the parties. No effective relief could be granted through a challenge to orders that had already been acted upon without addressing the consequences of restoration.

Conclusion: The question is answered in the negative. In the circumstances, the Department could not maintain its challenge to the implemented orders. This issue favours the assessee.

Issue (iii): Whether failure to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded the taxpayers from pursuing an appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: Filing an application for revocation under Rule 23 was not practically available after expiry of the prescribed period because the common portal did not permit such filing. The appellate remedy under Section 107 operates independently, and inability or failure to pursue revocation cannot extinguish the statutory right to challenge cancellation through appeal.

Conclusion: The Department's objection based on Rule 23 is rejected. The taxpayers were not barred from pursuing their statutory appellate remedy. This issue favours the assessee.

Final Conclusion: Although the condonation beyond the statutory limit was legally impermissible, the Department's implementation of the orders and restoration of registrations foreclosed an effective challenge in the present circumstances.

Ratio Decidendi: A statutory appellate authority cannot enlarge its time-condonation jurisdiction beyond an express statutory outer limit by relying on case-specific relief granted by a constitutional court in writ jurisdiction.

Issues: (i) Whether the FAA could condone an appeal filed beyond the outer limit in Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department's appeals remained maintainable after it implemented the FAA's orders by restoring registrations; and (iii) Whether the taxpayers' inability to pursue revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their appeals.

Issue (i): Whether the FAA could condone an appeal filed beyond the outer limit in Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Sections 107(1) and 107(4) prescribe the appeal period and the maximum further period for which delay may be condoned. The FAA, as a statutory authority, has no inherent or equitable power to enlarge that outer limit. Relief moulded by a High Court in constitutional writ jurisdiction under Article 226 of the Constitution of India does not enlarge the FAA's statutory jurisdiction; equity follows the law.

Conclusion: The FAA could not condone delay beyond the outer limit under Section 107(4); the condonation orders were ultra vires and coram non judice. This issue is decided in favour of Revenue.

Issue (ii): Whether the Department's appeals remained maintainable after it implemented the FAA's orders by restoring registrations.

Analysis: The Department restored the registrations pursuant to the impugned orders, following which the taxpayers resumed business and discharged statutory liabilities. These subsequent events left no effective or workable relief capable of being granted without unsettling the restored registrations and intervening transactions, rendering the departmental challenge academic.

Conclusion: The Department's appeals were not maintainable because no effective relief remained after implementation of the restoration orders. This issue is decided in favour of Assessee.

Issue (iii): Whether the taxpayers' inability to pursue revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their appeals.

Analysis: Once the prescribed period elapsed, the common portal did not permit filing of applications for revocation under Rule 23. That inability did not extinguish the independent statutory appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017.

Conclusion: Inability to seek revocation under Rule 23 did not bar the taxpayers from pursuing their appeals. This issue is decided in favour of Assessee.

Final Conclusion: The statutory limitation on the FAA's condonation power was affirmed, but the Department's implementation of the restoration orders meant that the taxpayers' active registrations and ensuing compliance were not unsettled.

Ratio Decidendi: An expressly capped statutory power to condone delay cannot be enlarged through equitable relief granted by a High Court in constitutional writ jurisdiction.

Issues: Whether an amalgamated company may carry forward and set off unutilised Minimum Alternate Tax credit of amalgamating companies under a sanctioned scheme of amalgamation.

Analysis: Section 115JAA permits credit for tax paid under the Minimum Alternate Tax regime. The sanctioned scheme transferred the amalgamating companies' tax rights and claims, including unutilised MAT credit, to the transferee company. Section 115JAA(7) expressly denies the credit only where a private or unlisted public company is converted into a limited liability partnership, without imposing a corresponding restriction on amalgamation. That specific prohibition cannot be extended by implication to an amalgamated company, which succeeds to the tax attributes of the amalgamating companies.

Conclusion: The amalgamated company is entitled to set off the unutilised MAT credit of the amalgamating companies, subject to verification of the quantum and availability of the credit in accordance with law.

Issues: (i) Whether the First Appellate Authority could condone appeals filed beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain appeals after implementing the impugned orders by restoring the taxpayers' registrations; and (iii) Whether the taxpayers' inability to seek revocation under Rule 23 barred their statutory appeals.

Issue (i): Whether the First Appellate Authority could condone appeals filed beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary period for appeal and Section 107(4) permits condonation only within the further statutorily specified period. Relief moulded by a High Court under Article 226 of the Constitution of India, in exercise of constitutional jurisdiction, cannot enlarge the statutory jurisdiction of the First Appellate Authority. Equity follows the law and cannot override an express limitation.

Conclusion: The First Appellate Authority lacked power to condone delay beyond the statutory outer limit under Section 107(4); this issue is answered in favour of Revenue.

Issue (ii): Whether the Department could maintain appeals after implementing the impugned orders by restoring the taxpayers' registrations.

Analysis: The Department restored the registrations pursuant to the impugned orders, after which the taxpayers resumed business and continued statutory compliance. Annulment at that stage would unsettle the restored registrations and transactions undertaken during the intervening period. The challenges consequently became academic and incapable of affording effective relief.

Conclusion: The Department could not maintain the challenges in the circumstances after implementing the impugned orders; this issue is answered in favour of the taxpayers.

Issue (iii): Whether the taxpayers' inability to seek revocation under Rule 23 barred their statutory appeals.

Analysis: The portal did not permit a revocation application after expiry of the prescribed period. The statutory remedy of appeal under Section 107 operates independently, and inability to invoke the revocation procedure does not extinguish the right to challenge cancellation in appeal.

Conclusion: The inability to seek revocation under Rule 23 did not bar the taxpayers' statutory appeals; this issue is answered in favour of the taxpayers.

Final Conclusion: The restored registrations and their consequential legal effect remain undisturbed, notwithstanding the finding that the First Appellate Authority exceeded its statutory condonation jurisdiction.

Ratio Decidendi: A statutory appellate authority cannot enlarge an express limitation period by relying on equitable considerations or relief granted by a constitutional court under Article 226.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the maximum condonable period prescribed under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain its appeals after implementing the impugned orders by restoring the taxpayers' registrations; (iii) Whether the inability or failure to seek revocation under Rule 23 precluded the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay beyond the maximum condonable period prescribed under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary period for appeal and Section 107(4) limits the further period for which delay may be condoned. The First Appellate Authority, being a statutory authority, possesses only the statutory jurisdiction conferred upon it. Relief moulded by a High Court under Article 226 of the Constitution of India cannot enlarge that jurisdiction. Equity follows the law and cannot override an express statutory limitation.

Conclusion: The First Appellate Authority could not condone delay beyond the statutory outer limit; the condonation and consequential appellate orders were without jurisdiction and ultra vires. This issue is decided in favour of Revenue.

Issue (ii): Whether the Department could maintain its appeals after implementing the impugned orders by restoring the taxpayers' registrations.

Analysis: The Department restored the registrations pursuant to the impugned orders, enabling the taxpayers to resume business and fulfil their compliance obligations. This subsequent development altered the legal and commercial position, and no effective relief could be granted without unsettling the restored registrations and intervening transactions.

Conclusion: The Department could not maintain the appeals after acting upon the impugned orders; the appeals had become infructuous and no effective relief was available. This issue is decided in favour of the assessee.

Issue (iii): Whether the inability or failure to seek revocation under Rule 23 precluded the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: Once the prescribed period had expired, the common portal did not permit an application for revocation under Rule 23. The statutory remedy of appeal under Section 107 is independent and the inability to pursue revocation does not extinguish the right to challenge cancellation in appeal.

Conclusion: The taxpayers were not precluded from pursuing the statutory appellate remedy. This issue is decided in favour of the assessee.

Final Conclusion: The statutory limit on the First Appellate Authority's power remained enforceable, but the Department's implementation of the restoration orders prevented it from obtaining an effective challenge, and the taxpayers' appellate remedy was not defeated by the lapse of the revocation period.

Ratio Decidendi: A statutory appellate authority cannot condone delay beyond an express outer limit prescribed by the statute, and equitable considerations or constitutional relief granted in another case cannot enlarge that authority's jurisdiction.

Issues: (i) Whether a statutory first charge under Section 48 of the Gujarat Value Added Tax Act, 2003 and pre-CIRP attachment proceedings conferred secured-creditor status under the Insolvency and Bankruptcy Code, 2016 after the Explanation to Section 3(31); (ii) Whether dues under the Central Sales Tax Act, 1956 constituted secured debt.

Issue (i): Whether a statutory first charge under Section 48 of the Gujarat Value Added Tax Act, 2003 and pre-CIRP attachment proceedings conferred secured-creditor status under the Insolvency and Bankruptcy Code, 2016 after the Explanation to Section 3(31).

Analysis: The Explanation inserted in Section 3(31) clarifies that a security interest exists only where a right in property arises from an agreement or arrangement involving two or more parties, and excludes an interest created merely by operation of law. Being clarificatory, the Explanation applies to pending proceedings. A statutory first charge under the GVAT Act arises solely by operation of law, while attachment proceedings are enforcement measures and do not create consensual security. Such statutory charge therefore cannot be equated with agreement-based security recognised by the Code.

Conclusion: The GVAT dues cannot be ranked as secured debt and must be treated as operational debt.

Issue (ii): Whether dues under the Central Sales Tax Act, 1956 constituted secured debt.

Analysis: The Central Sales Tax Act does not create a statutory first charge over the corporate debtor's assets. Section 9(2) of that Act does not create a security interest, and the CST component consequently has no basis for secured treatment.

Conclusion: The CST dues cannot be treated as secured debt and must be treated as operational debt.

Final Conclusion: The admitted statutory claim retains its admission but receives only the treatment available to operational creditors under the Code and the approved resolution plan, without secured-creditor waterfall priority.

Ratio Decidendi: Under the clarificatory Explanation to Section 3(31) of the Insolvency and Bankruptcy Code, 2016, only an agreement-based interest qualifies as a security interest; a statutory charge or attachment arising solely by operation of law cannot confer secured-creditor priority.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the maximum period prescribed under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain its challenge after implementing the impugned orders by restoring the taxpayers' registrations.

Issue (i): Whether the First Appellate Authority could condone delay beyond the maximum period prescribed under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary limitation period for an appeal, while Section 107(4) limits the First Appellate Authority's power to condone delay to the further period expressly stipulated. Relief moulded by a High Court under Article 226 of the Constitution of India, in the exercise of extraordinary constitutional jurisdiction, cannot enlarge the jurisdiction of a statutory appellate authority. Equity follows the law and cannot override an express statutory limitation.

Conclusion: The First Appellate Authority lacked jurisdiction to condone delay beyond the statutory outer limit; this issue is decided in favour of Revenue.

Issue (ii): Whether the Department could maintain its challenge after implementing the impugned orders by restoring the taxpayers' registrations.

Analysis: The Department implemented the impugned orders by restoring the registrations, following which the taxpayers resumed business and continued statutory compliance. Annulment at this stage would unsettle the restored registrations and intervening genuine transactions, while yielding no effective relief to the Department. The Department could not challenge the orders after acting upon and giving effect to them.

Conclusion: The Department's challenge was not maintainable and had become infructuous; this issue is decided in favour of the assessee.

Final Conclusion: Although the statutory limitation restricted the First Appellate Authority's condonation power, the Department's prior implementation of the restoration orders precluded an effective challenge in the circumstances of these cases.

Ratio Decidendi: A statutory appellate authority cannot enlarge its expressly limited power to condone delay by relying on equitable relief granted by a High Court under Article 226 of the Constitution of India.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department's appeals were maintainable after it implemented the impugned orders by restoring the registrations; (iii) Whether inability to seek timely revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred the taxpayers from appealing under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary period for appeal, while Section 107(4) permits condonation only within the further period expressly stipulated. A statutory authority has no inherent or equitable power to enlarge that outer limitation. Fact-specific relief granted by a High Court under Article 226 of the Constitution of India cannot extend the statutory appellate jurisdiction of the First Appellate Authority.

Conclusion: The issue is decided in favour of Revenue: the First Appellate Authority lacked jurisdiction to condone delay beyond the limit under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Issue (ii): Whether the Department's appeals were maintainable after it implemented the impugned orders by restoring the registrations.

Analysis: The Department implemented the impugned orders, restored the registrations, and thereby enabled the taxpayers to resume business and meet statutory obligations. The resulting subsequent developments altered the parties' legal and commercial position. Annulment of the orders after such implementation would yield no effective relief and would unsettle the restored registrations and intervening transactions.

Conclusion: The issue is decided in favour of Assessee: the Department could not maintain appeals seeking to annul orders that it had already implemented, and the appeals had become infructuous.

Issue (iii): Whether inability to seek timely revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred the taxpayers from appealing under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: As the common portal did not permit revocation applications after expiry of the prescribed period, compliance with Rule 23 was not practically available. The statutory appellate remedy under Section 107 remained an independent remedy, and non-utilisation of revocation could not extinguish the right to challenge cancellation in appeal.

Conclusion: The issue is decided in favour of Assessee: inability to invoke Rule 23 did not bar the taxpayers from pursuing the appellate remedy.

Final Conclusion: Although the condonation of delay exceeded the First Appellate Authority's statutory jurisdiction, the Department's implementation of the orders and restoration of registrations prevented any effective reversal in these matters.

Ratio Decidendi: A statutory appellate authority cannot rely on fact-specific relief granted under constitutional jurisdiction to enlarge its expressly limited power to condone delay.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the maximum period allowed by Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could challenge the appellate orders after implementing them by restoring the taxpayers' registrations; and (iii) Whether failure or inability to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded the taxpayers from pursuing their statutory appeals.

Issue (i): Whether the First Appellate Authority could condone delay beyond the maximum period allowed by Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes three months for filing an appeal and Section 107(4) permits condonation only for a further one month on sufficient cause. A statutory appellate authority possesses only the jurisdiction conferred by the statute. Relief moulded by a High Court under Article 226 of the Constitution of India in fact-specific circumstances cannot enlarge that statutory appellate jurisdiction. Equity follows the law and cannot override an express statutory limitation.

Conclusion: The First Appellate Authority lacked jurisdiction to condone delay beyond the statutory outer limit; such condonation and the consequential appellate orders were coram non judice and ultra vires. This issue is decided in favour of Revenue.

Issue (ii): Whether the Department could challenge the appellate orders after implementing them by restoring the taxpayers' registrations.

Analysis: The Department implemented the appellate orders, restored the registrations, and thereby enabled continuing business operations and compliance. These subsequent developments materially altered the parties' position. In the absence of any reversal or addressing of the consequences of restoration, annulment of the orders would yield no effective or workable relief and would unsettle intervening genuine transactions.

Conclusion: The Department could not maintain its challenge to the implemented appellate orders in the circumstances of these cases. This issue is decided against Revenue.

Issue (iii): Whether failure or inability to seek revocation under Rule 23 of the Central Goods and Services Tax Rules, 2017 precluded the taxpayers from pursuing their statutory appeals.

Analysis: Once the prescribed period had expired, the common portal did not permit applications for revocation under Rule 23. The revocation mechanism and the appellate remedy under Section 107 operate as alternative statutory remedies; inability or failure to use the former does not extinguish the right to challenge cancellation through the latter.

Conclusion: Failure or inability to invoke Rule 23 did not bar the taxpayers from pursuing their statutory appeals. This issue is decided in favour of the assessees.

Final Conclusion: The statutory jurisdictional limit governing condonation by the First Appellate Authority remains intact, but the Department's implementation of the restoration orders prevents their retrospective undoing in this batch.

Ratio Decidendi: A statutory appellate authority cannot invoke the extraordinary equitable jurisdiction exercisable by a High Court under Article 226 to extend an expressly capped period of limitation under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Issues: (i) Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017; (ii) Whether the Department could maintain appeals after implementing the impugned orders by restoring the taxpayers' registrations; (iii) Whether the taxpayers' inability to seek revocation within the period under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the First Appellate Authority could condone delay beyond the outer limit under Section 107(4) of the Central Goods and Services Tax Act, 2017.

Analysis: Section 107(1) prescribes the ordinary period for appeal and Section 107(4) limits the further period for which delay may be condoned. The First Appellate Authority, being a statutory authority, could exercise jurisdiction only within those limits. Orders of a High Court under Article 226 of the Constitution of India, issued in the exercise of extraordinary constitutional jurisdiction on their particular facts, could not enlarge the statutory appellate jurisdiction. Equity follows the law; it cannot override an express statutory limitation. Condonation beyond the prescribed outer limit was ultra vires and coram non judice.

Conclusion: The First Appellate Authority lacked jurisdiction to condone the delays beyond the statutory outer limit. This issue is decided against the assessees.

Issue (ii): Whether the Department could maintain appeals after implementing the impugned orders by restoring the taxpayers' registrations.

Analysis: The Department acted upon the impugned orders by restoring the registrations, following which the taxpayers resumed business and discharged their obligations. This material subsequent development left no effective relief capable of being granted in the Department's challenge. The Department's inconsistent conduct engaged the principle that a party cannot approbate and reprobate by implementing an order and subsequently seeking its annulment without addressing the consequences of that implementation.

Conclusion: The Department could not maintain its challenge to the orders after implementing them through restoration of registrations. This issue is decided in favour of the assessees.

Issue (iii): Whether the taxpayers' inability to seek revocation within the period under Rule 23 of the Central Goods and Services Tax Rules, 2017 barred their appeals under Section 107 of the Central Goods and Services Tax Act, 2017.

Analysis: The common portal did not permit applications for revocation after expiry of the prescribed period. The remedy of revocation under Section 30 and the appellate remedy under Section 107 operate as independent statutory remedies. The inability to pursue revocation under Rule 23 did not extinguish the right to challenge cancellation through appeal.

Conclusion: Non-compliance with Rule 23 did not bar the taxpayers from pursuing their statutory appeals. This issue is decided in favour of the assessees.

Final Conclusion: Although the statutory restriction on condonation of delay remains applicable, the restored registrations remain undisturbed because the Department's prior implementation of the impugned orders deprived its challenge of effective relief.

Ratio Decidendi: A revenue authority that has implemented an order restoring registration cannot subsequently pursue a challenge to annul that order where no effective relief can follow from such challenge.

Issues: Whether proceedings under Section 153C could be initiated where the satisfaction note did not link the alleged incriminating material to any particular assessment year.

Analysis: The satisfaction note merely recorded seizure of a hard disk and proposed initiation of proceedings for specified assessment years. It did not record how the seized material related to, or was relevant for, any particular assessment year. Such vague satisfaction was insufficient to assume jurisdiction under Section 153C.

Conclusion: Proceedings under Section 153C were invalid for want of a satisfaction note linking incriminating material to the relevant assessment years; the finding is in favour of the assessee.