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HC quashed the appellate authority's order rejecting petitioner's appeal as time-barred under CGST Act. Petitioner attempted filing appeal within statutory period under Section 107 but was prevented by system malfunction that rejected appeals where demanded tax was already paid. Despite petitioner's protest payment and timely filing attempt, authorities failed to address technical impediment. Court held denial of statutory remedy was attributable solely to respondents' defective system, not petitioner's conduct. Appellate authority erred in mechanically applying time limitation without considering circumstances preventing timely submission. HC directed restoration of appeal and consideration on merits, treating it as timely filed, recognizing petitioner's right to appeal remains despite tax payment under protest.
HC quashed the appellate authority's order rejecting petitioner's appeal as time-barred under CGST Act. Petitioner attempted filing appeal within statutory period under Section 107 but was prevented by system malfunction that rejected appeals where demanded tax was already paid. Despite petitioner's protest payment and timely filing attempt, authorities failed to address technical impediment. Court held denial of statutory remedy was attributable solely to respondents' defective system, not petitioner's conduct. Appellate authority erred in mechanically applying time limitation without considering circumstances preventing timely submission. HC directed restoration of appeal and consideration on merits, treating it as timely filed, recognizing petitioner's right to appeal remains despite tax payment under protest.
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