No condonation of delay in GST Appeal as statutory limitation u/s 107 (4) was absolute and couldn’t be extended

Moms Cradle Private Limited Vs Union of India & Anr. (Delhi High Court)

Conclusion: The strict 4-month statutory limitation period for filing a GST appeal under Section 107 could not be condoned, as the provision created a special regime that excluded the general principles of condonation of delay under the Limitation Act.

Held: Assessee-company was an exporter of readymade garments. The dispute arose from two separate writ petitions: one challenging the withholding of a GST refund and another seeking permission to file a delayed statuto

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