Statutory outer limits on condoning delay restrict the First...

Statutory outer limits on condoning delay restrict the First Appellate Authority's jurisdiction in GST registration-cancellation appeals; equitable considerations and fact-specific constitutional orders cannot extend that power. However, where the Department has already restored registrations pursuant to the challenged appellate orders, its challenge may become infructuous because reversing those orders without addressing the consequences of implementation offers no effective relief. Failure or inability to seek revocation through Rule 23, including where the common portal blocks a late application, does not extinguish the independent statutory right to appeal cancellation of GST registration.