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    <title>2026 (5) TMI 1504 - RAJASTHAN HIGH COURT</title>
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    <description>The ninety-day period for passing an appellate order under the Rajasthan GST law was treated as directory, because the statute provided no automatic consequence for delay and a mandatory reading would defeat the appellate remedy. Departmental appeals were found to be within time or validly condoned on the basis of actual receipt, and objections based on portal upload dates were rejected. The CGST authority was held competent to appeal, and manual filing was not fatal because electronic filing was facilitative rather than jurisdictional. Natural justice and estoppel objections also failed, as no legal prejudice was shown and there is no estoppel against statute in tax matters.</description>
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    <pubDate>Wed, 20 May 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=792302</link>
      <description>The ninety-day period for passing an appellate order under the Rajasthan GST law was treated as directory, because the statute provided no automatic consequence for delay and a mandatory reading would defeat the appellate remedy. Departmental appeals were found to be within time or validly condoned on the basis of actual receipt, and objections based on portal upload dates were rejected. The CGST authority was held competent to appeal, and manual filing was not fatal because electronic filing was facilitative rather than jurisdictional. Natural justice and estoppel objections also failed, as no legal prejudice was shown and there is no estoppel against statute in tax matters.</description>
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