Recovery of Tax — Since the petitioner has failed to avail the statutory remedy against the assessment orders within time, it is for the appellate authority to consider the applications for condonation of delay and it satisfied with the explanation, to condone the delay and to thereupon consider the sty application. — A. Divakaran Vs. The State Tax Officer (Works Contract), The Deputy Commissioner, State GST Department, Mattancherry, The Deputy Commissioner (Appeals) , State GST Department, Thevara, Ernakulam and The Assistant Commissioner, State GST Department, Muvattupuzha [2019] 11 TAXLOK.COM 077 (Kerala)