Delayed GST statutory appeals proceed on merits only after tax, interest and penalty deposit conditions are met.

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....Delayed statutory appeals against GST assessment orders may be pursued where the taxpayer undertakes to pay outstanding tax and interest and deposits 10% of the penalty. Upon compliance, the appellate authority must decide the appeal on merits without applying limitation. If the conditions are not met, tax recovery may proceed after due notice. The permission remains conditional on these payments.....