Statutory limitation for tax appeals bars condonation beyond the prescribed period, leaving the appeal time-barred.

An appeal under Section 84 of the Finance Act was treated as time-barred because it was filed after the initial three-month limitation period and also beyond the further three months that the Commissioner (Appeals) could condone. The appellate authority had no power to extend delay beyond that statutory limit, so dismissal for want of limitation was consistent with the governing framework. The appeal was therefore upheld as barred by time, and no relief was granted.

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Issues: Whether the appeal was rightly dismissed as time-barred for having been filed beyond the prescribed period of limitation under Section 84 of the Finance Act.

Analysis: The appeal had been filed beyond the initial period of three months and also beyond the further period of three months that could be condoned by the Commissioner (Appeals). The order recorded that the appellate authority had no power to condone delay beyond the statutory limit, and therefore the dismissal for want of limitation was in accordance with the governing legal framework.

Conclusion: The dismissal of the appeal as time-barred was upheld, and the appellant obtained no relief.

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