GST tax determination for April 2019 to March 2020 was held time-barred because the order-in-original was passed and uploaded after the statutory cut-off of 31.08.2024. The Department's explanation that the officer was handling a heavy workload did not cure the defect, since limitation went to the root of jurisdiction to impose tax liability. The appellate authority also erred in overlooking this jurisdictional infirmity and dismissing the appeal on delay. The original adjudication and appellate orders were set aside as unsustainable in law.
GST tax determination for April 2019 to March 2020 was held time-barred because the order-in-original was passed and uploaded after the statutory cut-off of 31.08.2024. The Department's explanation that the officer was handling a heavy workload did not cure the defect, since limitation went to the root of jurisdiction to impose tax liability. The appellate authority also erred in overlooking this jurisdictional infirmity and dismissing the appeal on delay. The original adjudication and appellate orders were set aside as unsustainable in law.
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