2026 (4) TMI 1219

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....eard finally. 4. This Petition has been filed against the order dated 04.11.2022 passed by Respondent No.3 and order dated 28.03.2024 passed by respondent No. 2 under Section 107(11) of the Chhattisgarh Goods & Services Tax Act, 2017 and attachment notice dated 16.01.2026. 5. At the outset, learned Counsel for the petitioner submits that Ministry of Finance, Department of Revenue, Central Board of Indirect Taxes and Customs, GST Policy Wing has already issued a circular i.e. Circular No. 224/18/2024-GST dated 11.07.2024 under the subject heading "Guidelines for recovery of outstanding dues, in cases wherein first appeal has been disposed of, till Appellate Tribunal comes into operation" and laid down the policy where the Appeal agains....

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....further submits that earlier also, prior to the amendment of the CGST Act, by Act 8 of 2023, which came into force with effect from 01.08.2023, a circular has been issued on 03.12.2019 whereby, limitation has already been extended. As per circular dated 11.07.2024, it is now mandatory that the tax payer also needs to file an undertaking/declaration with the jurisdictional proper officer that he will file Appeal against the said order of the appellate authority before the Tribunal, as and when it comes into operation and referred to relevant paras i.e. paras-5 & 6, which read as under:- "5. The taxpayer also needs to file an undertaking/declaration with the jurisdictional proper officer that he will file appeal against the order of ....

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....sub-section (1) of section 112 of the Central Goods and Services Tax Act, 2017, has notified 30th June, 2026 as the date up to which an appeal may be filed before the Goods and Services Tax Appellate Tribunal in respect of all cases where the order sought to be appealed against has been communicated to the person preferring the appeal before 1st April, 2026. In respect of orders communicated on or after 1st April, 2026, which is also adopted by the State Government vide notification dated 06.03.2026, the appeal shall be filed before the Appellate Tribunal within three months from the date of communication of such order. 8. He lastly submits that this petition may be disposed of granting liberty in favour of the petitioner to avail the al....