Condonation of delay must come from the authority empowered by statute; Collector could not admit the time-barred revision application.

The Bombay Sales Tax Act prescribed a four-month limitation period for filing a revision application, and a late filing remained barred unless delay could be condoned by the authority expressly empowered to do so. Section 22B vested that condonation power only in the Tribunal, not in the Collector of Sales Tax, so the Collector had no jurisdiction to admit the delayed revision. Section 22A and Section 12 of the Indian Limitation Act did not extend limitation for revision applications in the manner argued. The revision was therefore time-barred, and the Collector's refusal to entertain it was upheld.

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Issues: Whether the Collector of Sales Tax had power to condone delay in filing a revision application under the Bombay Sales Tax Act, and whether the revision application was barred by limitation.

Analysis: The limitation period for the revision application was four months under Section 22 of the Bombay Sales Tax Act, and the application was filed beyond time. Section 22B invested the power to condone delay only in the Tribunal and did not authorise the Collector of Sales Tax to admit a late revision application. Section 22A could not assist the applicant because Section 12 of the Indian Limitation Act did not apply to revision applications in the manner contended. The Collector therefore lacked jurisdiction to condone the delay.

Conclusion: The revision application was barred by limitation and the Collector's refusal to entertain it was upheld.

Ratio Decidendi: Where the statute confers the power to condone delay only on a specified authority, no other authority can exercise that power, and limitation cannot be extended by relying on a provision that does not apply to revision applications.

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