The Madras High Court has held that GST appeals should not be rejected as time-barred by reckoning the limitation period from the date of a detailed adjudication order when separate orders in Form GST DRC-07 were subsequently issued for the respective assessment periods.

The bench of Justice Senthilkumar Ramamoorthy found that the appellate authority had adopted an incorrect starting point for computing limitation and restored the taxpayer’s appeals for consideration on merits.

The petitioner/assessee challenged appellate orders that had rejected his statutory GST appeals on the ground of limitation. The underlying proceedings concerned orders passed under Section 74 of the Central Goods and Services Tax Act, 2017 and the Tamil Nadu Goods and Services Tax Act, 2017.

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The adjudicating authority had passed a common detailed order dated November 7, 2025, followed by separate orders in Form GST DRC-07 for different financial years. The writ petitions covered assessment periods ranging from FY 2018-19 to FY 2024-25. 

The petitioner subsequently filed statutory appeals before the appellate authority. However, the appeals were rejected solely on limitation, resulting in the taxpayer approaching the High Court under Article 226 of the Constitution. 

The High Court noted that the appeals had been filed approximately 28 days beyond the prescribed period of three months. Along with the appeals, the petitioner had also sought condonation of the delay.

The explanation offered was that the petitioner’s erstwhile consultant had failed to inform him about the adjudication orders. According to the petitioner, he became aware of the orders only when recovery proceedings were initiated on February 19, 2026. He thereafter engaged a new consultant and proceeded to file the statutory appeals. 

The crucial question before the High Court was therefore not merely whether there was a delay, but from which order or date the statutory limitation period had to be calculated.

The High Court found that the appellate authority had incorrectly calculated the limitation period by taking the date of the detailed common adjudication order as the starting point.

Justice Senthilkumar Ramamoorthy observed that the petitioner had placed before the Court the common detailed order, the separate DRC-07 orders and evidence regarding the dates on which the statutory appeals were filed. On examining those materials, the Court concluded that the appeals ought not to have been rejected by computing limitation from the date of the detailed order. 

This distinction assumes particular significance under the GST appeal mechanism because the DRC-07 is the document that communicates the summary of the demand/order for the relevant tax period. In the present case, the Court specifically took note of the fact that the detailed order was followed by separate DRC-07 orders relating to each assessment period. 

The Court also considered the petitioner’s explanation for the delay. The petitioner had stated that the earlier consultant did not communicate the order and that he became aware of the proceedings only after recovery action commenced on February 19, 2026.

After becoming aware of the proceedings, the petitioner engaged a new consultant and filed the appeals. The High Court found these circumstances sufficient to justify condonation of the delay.

The Court consequently held that interference with the appellate orders was warranted, particularly because the limitation period itself had been computed from an incorrect date. 

The Madras High Court accordingly set aside the impugned appellate orders. Having found sufficient cause, the Court condoned the delay and remanded the matters to the appellate authority for adjudication on merits.

The writ petitions were disposed of on these terms, with no order as to costs, and the connected miscellaneous petitions were closed. 

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