Delayed transport documents failed to validate intercepted goods, sustaining transit-state penalties where the claimed interstate destination remained...
Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
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Section 107(4) imposes an outer limit on the First Appellate Authority's power to condone delay in GST appeals against cancellation of registration. Constitutional and equitable writ jurisdiction under Article 226 is distinct from statutory appellate jurisdiction and cannot expand that prescribed limit; condonation beyond it is legally unsustainable. Where the Department has implemented appellate orders by restoring cancelled registrations, it alters the affected parties' legal and commercial position. A subsequent departmental challenge to those same orders may become academic and infructuous if no effective relief can be granted without disturbing the restoration, rendering the challenge not maintainable.
Section 107(4) imposes an outer limit on the First Appellate Authority's power to condone delay in GST appeals against cancellation of registration. Constitutional and equitable writ jurisdiction under Article 226 is distinct from statutory appellate jurisdiction and cannot expand that prescribed limit; condonation beyond it is legally unsustainable. Where the Department has implemented appellate orders by restoring cancelled registrations, it alters the affected parties' legal and commercial position. A subsequent departmental challenge to those same orders may become academic and infructuous if no effective relief can be granted without disturbing the restoration, rendering the challenge not maintainable.
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