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The total limitation period during which an appeal can be preferred before AAAR is 60 days from the date of advance ruling order.

Levy of GST — The Appellate Authority being a creature of the statue is empowered to condone a delay of only a period of 30 days after the expiry of the initial period for filing appeal. As far as the language of Section 100 of the CGST Act is concerned, the crucial words are “not exceeding thirty days” used in the proviso to sub-section (2). To hold that the Appellate Authority could entertain appeal beyond the extended period under the proviso would render the phrase “not exceeding thirty days” wholly otiose. No principle of interpretation would justify such a result. Therefore, AAAR is not empowered to condone the delay of 77 days in filing appeal. — Durga Projects & Infrastructure Pvt. Ltd., In Re… [2019] 19 TAXLOK.COM 079 (AAAR-Karnataka)

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