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The core question that arises in this petition is whether the Superintendent of State Tax being the authority which passed the order had the authority to condone the delay on the face of the petition filed under Section 161 of the state GST Act for rectifying the defects or errors in the impugned notice. The petitioner's contention in respect of the extension of the Limitation Act stands dismissed.

Jurisdiction under GST— The core question that arises in this petition is whether the Superintendent of State Tax being the authority which passed the order had the authority to condone the delay on the face of the petition filed under Section 161 of the TSGST Act for rectifying the defects or errors in the impugned notice and order. Such error is sourced in the tax invoice which has mentioned the name of the petitioner. It is apparent on the face of the section 161 of the TSGST Act that this is a complete code within itself and it has impliedly excluded the Limitation Act. Thus, what has been observed by the Superintendent of Taxes in the decision communicated by the reply dated 17.12.2019 does not suffer from any infirmity. Moreover, the Limitation Act will not apply automatically unless it is extended to the special statute such as TSGST Act inasmuch as law in this regard is absolutely unambiguous that except in the case of the suit, appeal or application in the court, the limitation of Act will not apply/extend for the local or special statute. Held that— Thus, the petitioner?s contention in respect of the extension of the Limitation Act stands dismissed. That apart, in the considered view of this court, the rectification as sought is not covered by Section 161 of the TSGST Act.