GST appeal time-bar and input tax credit proof: remand for fresh adjudication subject to 25% deposit from electronic cash ledger.

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....Expiry of statutory limitation for challenging a GST order was decisive where the petitioner failed to substantiate lawful availment of input tax credit and did not refute reliance on invoices from a supplier alleged to issue fake invoices; consequence: the matter was remitted for fresh adjudication. The adjudicating authority is directed to decide on merits subject to a protective condition requiring the taxpayer to deposit 25% of the disputed tax from its electronic cash register within thirty days, balancing revenue protection with the taxpayers opportunity for merits adjudication.....