2026 (9) TMI 161

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....4-BDR-GST ADJN dated 31.08.2023 received on 07.09.2023 passed by Respondent No.2 under Section 74 of the CGST Act, 2017 read with Rule 14 (2) of CGST Rules for the subject tax periods 2017-18. (Annexure 'B'). b) Stay the operation of the Summary of the Order issued in Form GST DRC 07 bearing No.ZD291223086014 dated 28.12.2023 issued by Respondent No.2 under Section 74 of the CGST Act for the subject tax periods 2017-18 (Annexure 'B-1'); c) Stay all recovery proceedings of the balance amount of the disputed tax(90% of Rs.18,55,287/-) amounting to Rs.16,69,758/- along with interest and equivalent penalty under Section 74 of the Act arising out of the Order of Adjudication or OIO bearing Order- in-Original No.07/2023-24-GST A....

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....me was challenged before the Appellate Authority, which rejected the appeal on the ground of limitation vide order dated 30.06.2026 at Annexure-A and the said orders are challenged in the present petition. 4. Learned counsel for the petitioner submits that non-filing of reply to the show-cause notice and to contest the proceedings was due to bonafide reasons, unavoidable circumstances and sufficient cause and as such, the 1st respondent proceeded to pass the impugned order, pursuant to which, petitioner filed an appeal on 07.03.2024 before the Appellate Authority, which was dismissed as barred by limitation vide impugned order dated 30.06.2026. Hence, the petitioner has no option but to approach this Court by way of the present petition ....