Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Section 107(4) CGST permits the appellate authority a discretionary additional one-month extension where an appellant is prevented by "sufficient cause" from filing within 90 days; that discretion ends with that 30-day window and cannot be expanded under Article 226. The court emphasises taxpayers' duty to monitor the GSTIN portal and rejects explanations of misunderstanding or lack of knowledge as insufficient to excuse delay. The court refused to entertain a belated challenge to a show-cause notice after an appeal was dismissed for delay and dismissed the writ petition.
Section 107(4) CGST permits the appellate authority a discretionary additional one-month extension where an appellant is prevented by "sufficient cause" from filing within 90 days; that discretion ends with that 30-day window and cannot be expanded under Article 226. The court emphasises taxpayers' duty to monitor the GSTIN portal and rejects explanations of misunderstanding or lack of knowledge as insufficient to excuse delay. The court refused to entertain a belated challenge to a show-cause notice after an appeal was dismissed for delay and dismissed the writ petition.
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