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    <title>2026 (2) TMI 386 - ALLAHABAD HIGH COURT</title>
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    <description>High Court applied the principle that limitation is abeyant during bona fide pursuit of rectification under the UPGST Act, treating time spent on a Section 161 rectification application as excluded from limitation; consequently an appeal filed after rectification rejection was held maintainable despite delay, relying on a Division Bench precedent. The Court found a separate appeal timely where the petitioner withdrew a writ with liberty to appeal and held the petitioner entitled to the benefit of limitation abeyance for pursuing remedy before a wrong forum. Because interim deposits (10% and 25% respectively) were made, the appellate authority must decide the appeals on merits within two months.</description>
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      <link>https://www.taxtmi.com/caselaws?id=786191</link>
      <description>High Court applied the principle that limitation is abeyant during bona fide pursuit of rectification under the UPGST Act, treating time spent on a Section 161 rectification application as excluded from limitation; consequently an appeal filed after rectification rejection was held maintainable despite delay, relying on a Division Bench precedent. The Court found a separate appeal timely where the petitioner withdrew a writ with liberty to appeal and held the petitioner entitled to the benefit of limitation abeyance for pursuing remedy before a wrong forum. Because interim deposits (10% and 25% respectively) were made, the appellate authority must decide the appeals on merits within two months.</description>
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