Section 107(4) imposes an outer limit on the First Appellate...

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.