Retrospective extension of the time limit for claiming input tax credit permits eligible registered persons to claim credit where returns were filed within the period prescribed under Section 16(5). A limitation-based denial under Section 16(4) cannot be sustained in such circumstances. The extended period applies retrospectively, allowing the taxpayer to obtain input tax credit despite the earlier time-bar objection, provided the statutory conditions for eligibility and timely return filing under the extended provision are met.

Further adjudication on merits is conditioned on the petitioner depositing an additional portion of the disputed tax within the stipulated period and filing a reply with supporting documents to the show-cause notice. The issue arises from non-participation in consequential proceedings after the death of the person who conducted the business, despite an earlier deposit of part of the disputed tax and expiry of appellate limitation. Upon compliance, the adjudicating authority must issue due notice and determine the matter on merits.

Personal hearing under Section 75(4) requires effective advance intimation of hearing dates through the common portal. Where the last three hearing dates are not communicated and that omission is undisputed, the mandatory hearing requirement is not met. The resulting breach requires fresh adjudication after adequate advance notice, preserving the petitioner's opportunity to be heard.

GST appellate delay arising from defective portal-based communication may warrant condonation where a show-cause notice and adjudication order are uploaded under a non-designated portal tab, preventing effective knowledge and resulting in an ex parte demand. Although the statutory appellate authority is confined by the prescribed limitation for condoning delay, portal uploading without acknowledgement or response may not constitute sufficient service in such circumstances. Denial of adjudication on merits would cause grave prejudice; accordingly, the delayed appeal was directed to be entertained and decided on merits.

Effective service of GST notices and adjudication orders through the designated portal tab is material to an assessee's ability to pursue a statutory appeal. Although section 107 of the Rajasthan and Central GST laws restricts the Appellate Authority's power to condone delay, uploading communications under an incorrect portal tab, followed by delayed recovery action, may establish lack of effective knowledge of the proceedings. In such circumstances, refusing merits adjudication would cause serious prejudice. The delay was condoned, allowing the assessee's appeal to be entertained and decided on merits if filed within the stipulated period.

Delay in filing a statutory GST appeal may be condoned where an ex parte order uploaded only on the common portal did not come to the taxpayer's knowledge within the prescribed limitation period. Although section 107 of the Rajasthan and Central GST laws binds the Appellate Authority to statutory timelines, portal-only uploading and the resulting lack of knowledge may constitute circumstances beyond the taxpayer's control. Restoring the appellate remedy prevents prejudice from denial of adjudication on merits, enabling the appeal to be entertained and decided on merits.

Writ jurisdiction was declined where a GST demand could be challenged through an available statutory appeal that had not been invoked. The petition was filed more than a year after the demand order, and neither the merits of the demand nor the alleged breach of natural justice was adjudicated. The petitioner was required to pursue the statutory appellate remedy.

Restoration of an appeal dismissed for non-appearance was addressed where the petitioner's auditor or tax consultant could not attend notified hearings. The stated inability to attend was treated as sufficient grounds to reopen the appellate proceedings, while protecting procedural discipline through costs and a direction to appear before the appellate authority. The dismissal order was set aside, the appeal was restored for adjudication on merits subject to payment of costs, and the merits remained open.

Section 107 of the Central Goods and Services Tax Act, 2017 provides a statutory appellate remedy against an Order-in-Original, and writ jurisdiction is ordinarily not invoked where that remedy remains unexhausted. A delay of 99 days beyond the prescribed appeal period was treated as arising from circumstances beyond the petitioner's control, constituting sufficient cause to permit access to the appellate remedy. The Appellate Authority must entertain and decide the appeal on merits if it is filed within 30 days of uploading of the order.

Cancellation of GST registration under Rule 21(b) for alleged issuance of invoices without supply requires a reasoned order that considers the registered person's material reply. Where the reply asserts that an earlier show-cause notice on the same grounds was dropped and no fresh particulars or queries were supplied, the cancellation order must address those objections rather than merely repeat allegations of circular transactions. Failure to consider the reply and provide reasons renders the cancellation unsustainable, requiring fresh consideration after an opportunity of hearing.

Availability of a statutory appeal under the CGST Act is material to the discretionary exercise of writ jurisdiction, even though it does not absolutely bar recourse to Article 226. Challenges to rejection of GST registration cancellation that require factual inquiry and examination of records should ordinarily proceed through the appellate remedy under Section 107. Writ jurisdiction was not exercised, and the applicant was relegated to the statutory appeal without any view on the merits of the registration dispute.

Section 16(2)(c)'s constitutional validity was already settled by Supreme Court precedent, leaving no basis to entertain a writ challenge on that ground. A final tax order subject to the statutory appellate mechanism should be challenged through that remedy rather than by writ petition. The writ petitions were dismissed, while preserving the petitioners' liberty to pursue the available statutory appeal against the final tax order.

Dismissal of a statutory appeal solely on limitation, without examination on merits, warranted interference where the petitioner claimed no actual intimation of a show-cause notice uploaded on the portal and later knowledge of the adjudication order. The communication circumstances established a prima facie basis for ensuring an effective opportunity of hearing and reconsideration on merits. The appellate and adjudication orders were set aside, with fresh reasoned adjudication directed after hearing the petitioner.

Portal-only uploading of a GST show-cause notice and adjudication order under the "Additional Notice and Orders" tab, without separate intimation, may deny the taxpayer an effective opportunity to respond. Where the taxpayer cannot access or respond to the notice and is not afforded a personal hearing, the adjudication process breaches principles of natural justice. The adjudication order was set aside and the matter required fresh adjudication after a personal hearing.

Rejection of an appeal as time-barred requires consideration of the grounds advanced in the delay-condonation application and reasoned findings on those submissions. Treating acceptance of a delayed appeal as automatically defeating statutory limitation provisions does not address the explanation offered for delay. Where the authority fails to consider the petitioner's stated grounds for a nine-day delay, rejection of condonation is unsustainable. The limitation issue must be reconsidered through a reasoned order after hearing the petitioner.

Condonation of delay in a statutory appeal was warranted where serious illness of the person responsible for business affairs constituted sufficient cause and was supported by medical material. Compliance with the mandatory pre-deposit requirement before filing reinforced the availability of the appellate remedy. Dismissing the appeal solely as time-barred despite sufficient cause and pre-deposit compliance would be unduly technical and render the statutory remedy illusory. The delay was condoned, the appellate dismissal was quashed, and the appeal was directed to be admitted and decided on merits.

Availability of a statutory appeal against rejection of a GST registration-cancellation application does not bar writ jurisdiction under Article 226, but strongly informs its discretionary exercise. Where the challenge requires resolution of disputed facts and appraisal of the record, the statutory Appellate Authority is the appropriate forum. The writ petition was therefore not entertained, with liberty to pursue the statutory appeal; the Appellate Authority must decide it independently of observations made in the writ proceedings.

Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.

Defective service of a GST show-cause notice and adjudication order through an incorrect common-portal tab justified condonation of delay in filing the GST appeal. Uploading a notice on the portal alone was treated as insufficient service where there was no acknowledgement or reply, and belated recovery action supported the taxpayer's claim that the order appeared under "Additional Notices and Orders" rather than the designated tab. Although the Appellate Authority was bound by the statutory limitation period, refusal to hear the appeal would cause grave prejudice where the delay arose from circumstances beyond the taxpayer's control. The appeal was directed to be entertained and decided on merits if filed within the stipulated period.

Sufficient cause supported condonation of delay in a GST appeal where the taxpayer lacked effective knowledge of the show-cause notice and adjudication order because they were uploaded under a non-designated portal tab. Although the Appellate Authority remained bound by the limitation prescribed under section 107 of the RGST/CGST Act, circumstances beyond the taxpayer's control and the risk of grave prejudice justified merits review. The delay was condoned, with a direction to entertain and decide the appeal on merits if filed within the stipulated period.