Validity of extended cross-objection filing period upheld where filing is limited to before final hearing of the appeal.

The phrase "at any time before the appeal is finally heard" in section 22(2A) of the Karnataka Sales Tax Act, 1957 was construed as limiting cross-objections to the period ending before final hearing of the appeal, rather than creating an indefinite filing window. The court treated the Legislature's decision to allow filing beyond thirty days as a matter of policy and declined to regard that time-frame as arbitrary merely because other statutes prescribe shorter limits. The provision was upheld as valid and not violative of Article 14.

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Issues: Whether the words "at any time before the appeal is finally heard" in section 22(2A) of the Karnataka Sales Tax Act, 1957 are unconstitutional as conferring an indefinite period for filing cross-objections and violating Article 14 of the Constitution of India.

Analysis: The provision was construed as not granting an unlimited period, because cross-objections can be filed only up to the stage before the appeal is finally heard. The Legislature's choice to permit filing beyond thirty days was treated as a matter of legislative policy and wisdom, and the Court declined to treat that choice as arbitrary merely because other enactments prescribe a shorter period.

Conclusion: The provision was held to be valid and not violative of Article 14 of the Constitution of India.

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