Section 107 of the CGST Act — Appeal – Time Period-- The  petitioner challenged the order dated 08.04.2022, issued under section 73 and consequential Demand Notice dated 10.04.2022. The court observed that the Order impugned is appealable under Section 107 of the Act. The counsel for the petitioner submitted that the remedy of appeal is time barred. The court observed that it would be inappropriate if not impermissible in law to entertain a petition under Article 226 of the Constitution of India on the ground that the statutory remedy is time barred. This would put a premium on the laxity and indeed dishonesty since all that would have to be done by litigant intending to bye-pass the statutory remedy, for whatever reason, would be to let the period of limitation expire and then approach the constitutional Court.

Held that:- The Hon’ble High Court dismissed the petition.