GST appeal limitation may yield where uncontrollable delay would deny merits review and cause grave prejudice.

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....Statutory limitation for GST appeals under section 107 bound the appellate authority, but the High Court condoned delay where circumstances beyond the taxpayer's control prevented timely filing and refusal of merits review would cause grave injury and prejudice. The appellate order dismissing the appeal as time-barred was set aside. The GST appeal concerning alleged wrongful availment of input tax credit was permitted to be filed and decided on merits without limitation objection, subject to compliance with the filing period stipulated by the High Court.....