Rakesh Ranjan Vs State of Bihar (Patna High Court)
In the case of Rakesh Ranjan vs. State of Bihar, the petitioner challenged orders passed under Section 73 of the Bihar Goods and Services Tax Act, 2017 (BGST Act) for the assessment year 2020–2021. The appellate authority dismissed his appeal due to a delay that exceeded the statutory limit. While the petitioner sought to invoke the Supreme Court’s limitation extension due to the pandemic, the court clarified that the final appeal filing deadline was 28 June 2022, but the petitioner filed on 19 July 2022. As a result, the court concluded it lacked the jurisdiction to condone delays beyond statutory limits.
The petitioner also argued that the orders lacked a digital signature as required under Rule 26(3) of the BGST Rules. However, the court emphasized that the statute allows alternate methods of authentication, and technical lapses, such as missing signatures, do not invalidate proceedings if they conform substantially to the law. Additionally, the petitioner failed to raise this issue at earlier stages of the proceedings. The court dismissed the writ petition, citing procedural deficiencies and statutory limitations.
This judgment reinforces the importance of adhering to statutory timelines and procedural requirements in GST-related appeals, particularly under the BGST Act.
