Statutory Limits on GST Appeal Delays Prevent Late Condonation, While Registration Restoration Makes Departmental Challenges Infructuous

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....Statutory limits on condonation of delay confine the First Appellate Authority's jurisdiction in GST registration-cancellation appeals. Extraordinary equitable relief available in constitutional jurisdiction cannot expand a statutory appellate authority's power or permit condonation beyond the prescribed outer limit; appeals entertained on that basis are without jurisdiction. However, where the Department has implemented the appellate orders by restoring cancelled GST registrations, it cannot seek their annulment without addressing the resulting legal and commercial consequences. Restoration renders departmental challenges ineffective, academic and infructuous, so no effective appellate relief remains available.....