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GST appeal limitation must be computed from a reasoned rectification order under section 161 where the rectification application was filed within the prescribed period and duly decided. The rectification proceedings directly affect the limitation period for challenging rejection of a refund claim; the Appellate Authority cannot calculate limitation solely from the original adjudication order. Rejection of the refund appeals as time-barred on that basis was impermissible. The appellate orders were quashed, and the matters were remanded for fresh adjudication on merits after hearing the petitioners.
GST appeal limitation must be computed from a reasoned rectification order under section 161 where the rectification application was filed within the prescribed period and duly decided. The rectification proceedings directly affect the limitation period for challenging rejection of a refund claim; the Appellate Authority cannot calculate limitation solely from the original adjudication order. Rejection of the refund appeals as time-barred on that basis was impermissible. The appellate orders were quashed, and the matters were remanded for fresh adjudication on merits after hearing the petitioners.
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