GST appellate jurisdiction to condone delay is confined to the...

GST appellate jurisdiction to condone delay is confined to the statutory outer limit under section 107(4). High Court writ jurisdiction under Article 226 may mould relief on particular facts, but it does not expand the First Appellate Authority's statutory power; equity and hardship cannot override the prescribed limitation period. Where the Department has implemented an appellate restoration of GST registration, thereby altering taxpayers' legal and commercial position, a subsequent departmental challenge may become infructuous unless the consequences of restoration can be effectively addressed. In such circumstances, no workable relief may be available despite the jurisdictional defect in condoning delay.