Rajasthan High Court Excuses 325-Day GST Appeal Delay Caused by Unnotified Portal Uploads
The Rajasthan High Court recently delivered a crucial judgment in the case of Shri Om Casting Vs Assistant Commissioner, offering significant relief to an assessee who missed the statutory appeal deadline. The core of the dispute revolved around the tax department's practice of uploading adjudication orders exclusively on the GST portal without parallel communication through traditional or direct electronic channels.
This judicial summary breaks down the factual background, the arguments presented by both the revenue and the assessee, and the ultimate ruling that underscores the importance of substantive justice over procedural technicalities.
Factual Matrix of the Dispute
In the present matter, the assessee was burdened with a tax liability amounting to ₹7,88,852 pertaining to the financial year 2018-19. This liability stemmed from allegations of claiming excess Input Tax Credit. The initial Order-in-Original establishing this demand was issued on 30.04.2024.
Seeking to challenge this demand, the assessee attempted to file a statutory appeal on 19.07.2025. However, the Appellate Authority summarily dismissed this appeal via an order dated 24.07.2025. The dismissal was grounded strictly on the premise of limitation, with the authority stating it possessed no legal mandate to excuse such a prolonged delay under the existing tax framework. Aggrieved by this rejection, the assessee approached the High Court by filing a writ petition.