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Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review. 
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Issues: Whether the appeal filed before the appellate authority beyond the statutory period was liable to be entertained or condoned.
Analysis: The appeal against the penalty order was filed after the expiry of the prescribed limitation period under the Customs Act. The statutory scheme allowed the appellate authority to admit an appeal only within the original period and, on sufficient cause being shown, within a further limited period of three months. It did not confer power to condone delay beyond that outer limit. As the appeal was filed after about six months from communication of the order, the appellate authority had no jurisdiction to entertain it on merits or extend limitation further.
Conclusion: The appeal was correctly held to be time-barred and the dismissal of the appeal was justified.
Ratio Decidendi: Where a statute prescribes an appeal period with only a limited additional period for condonation, the appellate authority cannot entertain an appeal filed beyond the maximum permissible period, even if sufficient cause is alleged.