In an important development concerning GST litigation, the Principal Bench of the Goods and Services Tax Appellate Tribunal (GSTAT), New Delhi, has initiated proceedings to examine a significant legal issue relating to the maintainability of appeals filed beyond the statutory condonation period prescribed under Section 112 of the Central Goods and Services Tax (CGST) Act, 2017.
The issue has arisen in Appeal No. Appeal/PB/D17/2026 titled Commissioner of CGST, Noida Commissionerate v. M/s Om Sai Hardware Sanitary and Paints, wherein the Hon’ble President of the GSTAT observed that disputes involving limitation beyond the statutory condonation cap are likely to arise in a large number of appeals across various States.
Recognising the wider legal implications, the Hon’ble President directed the Registry to prepare a comprehensive scrutiny report of the matter and to obtain information from all GSTAT State Benches regarding similar appeals involving identical questions of law. The objective is to assess the nationwide impact of the issue and facilitate uniform adjudication.
Pursuant to the directions of the Tribunal, the matter has been listed before the Special Bench, Principal Bench, GSTAT, New Delhi, for hearing on 01 July 2026, as communicated through Notice No. GSTAT/PB/00124/2026 dated 19 June 2026.
The proceedings before the Special Bench are expected to have far-reaching implications for taxpayers whose appeals before the GSTAT have been filed beyond the statutory period, particularly in cases where the delay exceeds the maximum condonable period prescribed under Section 112 of the CGST Act, 2017.
Tax professionals, departmental authorities, and taxpayers are advised to closely monitor the outcome of the Special Bench proceedings, as the decision may provide important guidance on the interpretation of limitation provisions and the Tribunal’s jurisdiction in cases involving delayed appeals.
This development is being viewed as one of the most significant procedural issues presently before the GST Appellate Tribunal and may influence the treatment of numerous pending appeals involving limitation across the country.
Reference:
- Notice No.: GSTAT/PB/00124/2026
- Date: 19 June 2026
- Appeal No.: Appeal/PB/D17/2026
- Case: Commissioner of CGST, Noida Commissionerate v. M/s Om Sai Hardware Sanitary and Paints
- Forum: Special Bench, Principal Bench, GSTAT, New Delhi
- Date of Hearing: 01 July 2026
Disclaimer: The above update is based on the GSTAT Notice dated 19.06.2026 and the proceedings recorded by the Principal Bench. The matter is presently pending consideration before the Special Bench, and no final judicial determination has yet been rendered on the issue.
