Period for filing appeal against AAR order to be counted from Original Order & not from date of ROM rejection order

In re NMDC Ltd (GST AAAR Karnataka) An appeal can be filed before the Appellate Authority only against an advance ruling pronounced in terms of Section 98(4). In this case, the ruling pronounced in terms of Section 98(4) is the advance ruling order No KAR ADRG 69/2019 dated 21-09-2019. An appeal is maintainable only against the said order dated 21-09-2019 within the statutory period of 30 days from the date of communication of the said order. However, no appeal has been filed before us against the advance ruling dated 21-09-2019. The Appellant contends that the order rejecting the ROM applicat...