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Section 107 confines the First Appellate Authority's power to condone delay in GST registration-cancellation appeals to the prescribed outer limit; condonation beyond that limit, and the resulting allowance of taxpayers' appeals, is without jurisdiction. Fact-specific relief granted by a High Court under Article 226 cannot enlarge the statutory appellate authority's jurisdiction. However, after the Department implemented the appellate orders by restoring GST registrations, it altered the taxpayers' legal and commercial position. As no effective or workable relief could then follow from annulling those orders, the departmental appeals were infructuous and not maintainable.
Section 107 confines the First Appellate Authority's power to condone delay in GST registration-cancellation appeals to the prescribed outer limit; condonation beyond that limit, and the resulting allowance of taxpayers' appeals, is without jurisdiction. Fact-specific relief granted by a High Court under Article 226 cannot enlarge the statutory appellate authority's jurisdiction. However, after the Department implemented the appellate orders by restoring GST registrations, it altered the taxpayers' legal and commercial position. As no effective or workable relief could then follow from annulling those orders, the departmental appeals were infructuous and not maintainable.
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