Extraordinary writ jurisdiction cannot revive a time-barred statutory GST appeal merely because appellate limitation has expired.

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....Extraordinary writ jurisdiction was declined where the taxpayer's statutory appeal against a GST demand had become time-barred. The notes state that the taxpayer submitted a physical reply to the show-cause notice because the portal had earlier been handled by a chartered accountant, but the final order recorded no reply and confirmed the demand. A rectification application under the GST Act remained pending but also appeared time-barred. The High Court dismissed the writ petition, stating that expiry of the statutory appellate limitation did not justify exercising jurisdiction under Article 226.....