https://www.taxtmi.com/article/detailed?id=16506 Procedural timelines under the GST framework were construed as directory rather than mandatory where the statute did not prescribe a consequence for delay. The ninety-day period for deciding appeals under Section 101(2) of the CGST Act was treated as intended to promote expeditious disposal and administrative discipline, not to extinguish appellate rights merely because the period was exceeded. The interpretation was guided by settled principles distinguishing mandatory and directory provisions, with emphasis on legislative intent, statutory purpose, and the need to avoid an interpretation that defeats substantive rights through procedural rigidity. Limitation and service issues arising from GST portal upload, electronic communication, and actual receipt were addressed in the context of departmental appeals against an advance ruling. Portal upload was not treated as the sole determinative factor for communication where actual receipt by the concerned authority was relevant. Delay condonation was treated as a valid statutory exercise of discretion. en-us Wed, 27 May 2026 07:29:53 +0530 Wed, 27 May 2026 07:29:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=16506 Procedural timelines under the GST framework were construed as directory rather than mandatory where the statute did not prescribe a consequence for delay. The ninety-day period for deciding appeals under Section 101(2) of the CGST Act was treated as intended to promote expeditious disposal and administrative discipline, not to extinguish appellate rights merely because the period was exceeded. The interpretation was guided by settled principles distinguishing mandatory and directory provisions, with emphasis on legislative intent, statutory purpose, and the need to avoid an interpretation that defeats substantive rights through procedural rigidity. Limitation and service issues arising from GST portal upload, electronic communication, and actual receipt were addressed in the context of departmental appeals against an advance ruling. Portal upload was not treated as the sole determinative factor for communication where actual receipt by the concerned authority was relevant. Delay condonation was treated as a valid statutory exercise of discretion. Articles Goods and Services Tax - GST Wed, 27 May 2026 07:29:53 +0530 https://www.taxtmi.com/article/detailed?id=16506