Statutory delay limits in GST appeals remain binding, but restored registrations can render departmental challenges infructuous.

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....Statutory appellate authorities may condone delay in GST appeals only within the enactment's prescribed outer limit; equitable considerations or High Court directions issued under extraordinary jurisdiction cannot enlarge that power. Where the Department implemented an appellate order by restoring cancelled GST registrations, its subsequent challenge became infructuous because reversal could disrupt intervening transactions and input tax credit without workable consequential relief. Taxpayers retain an independent right to appeal registration cancellation when the common portal prevents a delayed revocation application; failure to seek revocation under Rule 23 does not extinguish that appellate remedy.....