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First Appellate Authority cannot condone delay beyond the statutory outer limit for appeals against GST registration cancellation. Constitutional directions tailored to individual cases cannot enlarge statutory appellate jurisdiction or override an express limitation. The Department's restoration of cancelled registrations after implementing appellate orders altered taxpayers' legal and commercial positions; its challenges to those orders therefore became academic, futile, infructuous and not maintainable, as no effective relief could be granted without addressing the consequences of restoration.
First Appellate Authority cannot condone delay beyond the statutory outer limit for appeals against GST registration cancellation. Constitutional directions tailored to individual cases cannot enlarge statutory appellate jurisdiction or override an express limitation. The Department's restoration of cancelled registrations after implementing appellate orders altered taxpayers' legal and commercial positions; its challenges to those orders therefore became academic, futile, infructuous and not maintainable, as no effective relief could be granted without addressing the consequences of restoration.
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