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GST - Limitation Period for Appeal - Exclusion of Time in Rectification Proceedings under Section 14 of Limitation Act - Scope of Rectification Petitions under Section 161 of the CGST Act, 2017 - Petitioner case that time spent in prosecuting a rectification petition is liable to be excluded while computing the period of limitation for filing a statutory appeal under Section 107 of the CGST Act, 2017 - Whether principles underlying Section 14 of the Limitation Act apply to proceedings before appellate authorities under Section 107 of the CGST Act - HELD - The Limitation Act per se does not apply to quasi-judicial bodies, but the principles underlying the Limitation Act, particularly Section 14, do apply to proceedings before GST appellate authorities. GST enactments neither expressly nor implicitly exclude the application of principles underlying Section 14 of the Limitation Act - The term “other cause of a like nature” is not confined to causes falling within the same genus as defects of jurisdiction and extends to rejection of rectification petitions on the ground that no error is apparent. Time spent in pursuing a rectification petition in good faith and with due diligence can be excluded from the limitation period prescribed under Section 107, provided the petitioner satisfies all requisite conditions including that both proceedings relate to the same matter and were pursued between the same parties with due diligence and in good faith. Good faith requirement entails a broad examination of the rectification petition to determine whether there was some basis for lodging it - Rejection of a rectification petition on merits is not a full-fledged examination but qualifies as a bona fide mistaken remedy falling within the scope of other cause of a like nature, warranting exclusion of time. The extent of exclusion includes the entire time consumed from filing of rectification petition to date of rejection thereof. For purposes of evaluating exclusion under Section 14, it is necessary to examine each individual case to determine whether the petitioner has established entitlement to exclusion – In view of the facts of individual cases, seven writ petitions are allowed with direction to appellate authorities to receive and dispose appeals on merits; time exclusion granted in matters with rectification grounds meeting criteria of good faith and due diligence; certain cases remanded with specified remittance conditions; remaining cases dismissed – Ordered accordingly
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