The Tribunal held that a statutory authority cannot transplant the extraordinary jurisdiction of a High Court into its own limited powers, but also found the Department's challenge an afterthought since it had already acted upon the very orders it now challenges.

In a batch of sixteen appeals, the Goods and Services Tax Appellate Tribunal, Hyderabad Bench, has delivered a consolidated ruling holding that the First Appellate Authority exceeded its jurisdiction by condoning delay beyond the statutory outer limit of four months, but simultaneously dismissing all appeals as infructuous since the Department had already restored the registrations pursuant to the impugned orders [Mandalaneni Srinivasarao v. Krushi Electrical & Civil Works — Batch of 16 Appeals].

The Bench of A P Ravi (Judicial Member) and Duvvuri Krishna Srinivas (Technical Member) drew a careful distinction between the extraordinary constitutional jurisdiction of the High Court under Article 226 and the limited statutory jurisdiction of the FAA. The Tribunal observed that the FAA's reliance on the Telangana High Court orders in Southern Enterprises and Chenna Krishnama Charyulu Karampudi was misplaced — those orders were rendered in constitutional jurisdiction on peculiar facts and could not enlarge the FAA's statutory power.

The Tribunal characterised the condonation as coram non judice and ultra vires the Act, observing that what cannot be done directly under the statute cannot be achieved indirectly by invoking equitable considerations.

Notwithstanding this finding, the Tribunal held the appeals had become infructuous. All respondents had discharged their dues and their registrations remained active. Relying upon Union of India v. Dharampal Satyapal, the Tribunal held that allowing the appeals now would imperil genuine transactions and ITC availed by recipients — all through no fault of their own.

In a pointed observation, the Tribunal recorded that the Department displayed serious negligence — it ought to have either sought relief before the High Court or acted consistently with its acceptance of the orders, rather than implementing them and then challenging them after the constitution of the Tribunal.

The Tribunal also rejected the Revenue's contention regarding non-compliance with Rule 23, noting that the common portal had not permitted revocation applications after the prescribed period elapsed, and that the remedy under Section 30 does not extinguish the independent appellate right under Section 107.

2026-juristway.com-2934-GSTAT(Hyderabad)-GST  |  GSTAT, Hyderabad  |  APL/85/HYD/2026 (Batch of 16 Appeals)  |  18.09.2026