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of The AAAR held that the time limit for passing an order u/s 101 of the CGST Act, 2017 is not mandatory, and the word 'shall' should be interpreted in an advisory manner to avoid denying the right of appeal. The appeals were filed within the statutory period and not barred by limitation. Manual filing of appeals is allowed u/r 107A of the CGST Rules, 2017. Both central and state GST authorities are proper authorities to file an appeal against an advance ruling. The appellant can revisit their stance taken before the AAR, and the principle of estoppel does not apply. The preliminary objections raised by the respondent were rejected, and the appeals were held maintainable to be decided on merits. The case pertains to the valuation of GTA services and inclusion of the value of diesel provided by the service recipient.
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