Laxmi Motors Vs State of M.P. And Others (Madhya Pradesh High Court)
MP High Court Rules on GST Appeal Limitation: Appeal Filed in 4th Month is Valid After Applying General Clauses Act & Supreme Court Precedent
Summary
The Madhya Pradesh High Court, in the case of Laxmi Motors Vs State of M.P. And Others, addressed a significant point of law concerning the proper method for calculating the statutory period of limitation for filing an appeal under the Central Goods and Services Tax Act, 2017 (CGST Act). The core issue revolved around the Appellate Authority’s decision to dismiss the petitioner’s appeal as time-barred, based on an allegedly flawed computation of the four-month limitation period.
Factual Background and Authority’s Decision
The petitioner, Laxmi Motors, challenged an order passed by the Appellate Authority and Joint Commissioner, State Taxes, Satna Division, dated August 13, 2025. This order had dismissed the petitioner’s underlying appeal—filed on November 25, 2024—against an original penalty order issued on July 26, 2024. The Appellate Authority had concluded that the appeal was barred by limitation. The State’s counsel later confirmed that the Authority had computed the limitation period as 120 days, finding the appeal to be barred by two days.
Petitioner’s Argument and Statutory Interpretation
