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RU
Limitation for GST Appeals where Multiple DRC-07s follow a Common Section 74 Order
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(04.08.2026), the Madras High Court considered GST appeals arising from a common Section 74 adjudication order dated 07.11.2025 covering multiple financial years, followed by separate Form GST DRC-07s dated 17.11.2025 for each year.
The Appellate Authority rejected the appeals on 21.04.2026 by computing limitation from the common order.
It held that computing limitation from the common order would be legally untenable and contrary to principles of natural justice.
38-44/2026 dated 21.04.2026 dismissed all the appeals solely on the ground of bar of limitation, computing limitation from the date of the common order dated 07.11.2025.
Department cannot take advantage of its own practice of issuing a common order followed by staggered DRC-07s to defeat the right of appeal.