Certified-copy limitation period runs from the posting date where registered post is an approved mode of application.

Where a revision rule permits a certified-copy application to be sent by registered post, the relevant date for limitation is the date of posting, not the date of receipt by the authority. The postal transit period is beyond the applicant's control and forms part of the "time requisite" for obtaining the copy. Applying the principle underlying section 12(2) of the Limitation Act, 1963, the time taken in transit cannot be treated differently from a personally delivered application made on the same date. The exclusion of copy-obtaining time was therefore computed from the posting date.

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Issues: Whether, for computing the period excluded as the time requisite for obtaining a certified copy required to accompany a revision petition, the relevant date is the date on which the application for copy is posted by registered post or the date on which it is received by the authority concerned.

Analysis: The revision rules permitted an application for certified copy to be made by registered post and required the revision petition to be accompanied by the copy. The statutory scheme contained no express provision for exclusion of copy-obtaining time, but the principle underlying section 12(2) of the Limitation Act, 1963 applied. The expression "time requisite" means the time beyond the party's control occupied in obtaining the copy. Where the applicant avails of the prescribed mode of applying by registered post, the postal interval is not attributable to the applicant and cannot be treated differently from an application made personally on the same date.

Conclusion: The relevant date is the date of posting of the application by registered post, and the time taken in postal transit is includible in the time requisite for obtaining the certified copy. The question was answered in favour of the assessee.

Ratio Decidendi: When a statute or rule authorises application for a certified copy by registered post, the interval taken by the postal process is time beyond the applicant's control and is excluded as part of the time requisite for obtaining the copy for limitation purposes.

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