2026 (3) TMI 828

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....najan Das, Advocate. For the Opposite Parties: Mr. Sunil Mishra, Standing Counsel. ORDER 1. The instant writ petition is filed by the petitioner assailing the order passed by the Additional Commissioner of CT and GST (Appeal), Rourkela in rejecting an application for condonation of delay and consequently the appeal itself, as the delay is beyond the maximum outer-cap fixed under Section 1....

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....ub-Section (1) of Section 107 of the said Act manifestly indicates that the prescribed period of three months would start from the day when the said decision or order is communicated to such person. Thus, the communication of the order is sine qua non to ascertaining the period of limitation and there is no doubt in our mind that if the appeal is filed under the aforesaid provision within the time....

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....gard, it would be deemed to have been so communicated and the period of limitation would start from the said date. 6. The appellate authority did not find any substance in the stand of the petitioner that the said order was made known to the appellant on 14th June, 2024 when the bank account was attached on the basis of an order passed by the proper officer and found that the appeal being filed....