Strict statutory limitation barred a delayed tax appeal where no power existed to condone delay beyond the prescribed period.

Where the Karnataka Sales Tax Act, 1957 prescribed a 30-day period for filing an appeal under section 20(2), the appellate authority had no power to condone delay beyond that statutory limit. An appeal filed after an inordinate delay of 826 days was therefore treated as not maintainable and time-barred, and the rejection of the appeal was upheld. The text emphasizes that, absent express statutory authority to extend time, a delayed tax appeal cannot be entertained and the limitation bar operates strictly.

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Issues: Whether the appeal against the assessment-related order was barred by limitation and whether the appellate authority had power to condone the inordinate delay.

Analysis: The appeal was filed after an inordinate delay of 826 days. Under section 20(2) of the Karnataka Sales Tax Act, 1957, an appeal had to be filed within 30 days from the date of the assessment order. The Court noted that the jurisdictional appellate authority had no power to condone delay beyond the statutory limit and that the first appellate authority had rightly rejected the matter as time-barred. The writ court's view affirming that order disclosed no error of law or material irregularity.

Conclusion: The delay was not condonable and the rejection of the appeal as barred by limitation was upheld.

Ratio Decidendi: Where the statute prescribes a fixed period for appeal and does not confer power to condone delay beyond that period, an appeal filed after the statutory limit is not maintainable and must be rejected as time-barred.

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