Limitation Act condonation excluded in revision under Delhi sales tax law; delay cannot be condoned beyond express statutory limits.

Section 5 of the Limitation Act, 1963 does not apply to revision proceedings under section 47 of the Delhi Sales Tax Act, 1975 because section 62(2) confines limitation computation to sections 4 and 12 only. The special statute therefore excludes any broader condonation power by implication, and the revisional authority, being a quasi-judicial tribunal, has no jurisdiction to condone delay beyond what the Act expressly permits. Rule 36(4) of the Delhi Sales Tax Rules, 1975, read with rule 39, governs condonation in appeals but does not extend that power to revisions where the parent Act withholds it.

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Issues: Whether section 5 of the Limitation Act, 1963 applies to a revision application under section 47 of the Delhi Sales Tax Act, 1975 and whether the revisional authority can condone delay in filing such revision.

Analysis: Section 47 of the Delhi Sales Tax Act, 1975 prescribes the period for filing a revision application and section 62(2) expressly provides that, in computing limitation under section 47, only sections 4 and 12 of the Limitation Act, 1963 apply. The scheme of the special statute therefore shows that the Legislature intentionally limited the extent to which the Limitation Act would operate. The revisional authority under the Act is a tribunal exercising quasi-judicial power and not a court; in such proceedings section 5 cannot be invoked unless the special law expressly or by necessary implication permits it. Rule 36(4) of the Delhi Sales Tax Rules, 1975 only prescribes procedure for condonation in appeals and, through rule 39, does not enlarge the revisional authority's power where the Act itself excludes such power.

Conclusion: Section 5 of the Limitation Act, 1963 does not apply to revision proceedings under section 47 of the Delhi Sales Tax Act, 1975, and the revisional authority has no jurisdiction to condone delay beyond what sections 4 and 12 permit.

Ratio Decidendi: Where a special fiscal statute expressly limits the application of the Limitation Act to specified provisions, the omitted provisions stand excluded and delay cannot be condoned by implication.

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