Limitation in tax appeals bars interference where delayed filing cannot be entertained beyond the prescribed period.

The Tribunal's refusal to entertain a delayed appeal and the Commissioner (Appeals)'s condonation issue were held to raise no substantial question of law. The High Court noted that the Tribunal had relied on the Supreme Court's decision in Singh Enterprises, which governed the limitation point and supported the view that the appellate authority could not entertain the appeal beyond the prescribed period. In these circumstances, the challenge to the limitation ruling failed and no interference was warranted on condonation of delay or appellate competence.

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Issues: Whether the appeal raised any substantial question of law on the Tribunal's refusal to entertain the delayed appeal and the condonation of delay before the Commissioner (Appeals).

Analysis: The challenge to the Tribunal's view on limitation was rejected because the issue stood covered by the decision of the Supreme Court in Singh Enterprises, which had been relied upon by the Tribunal. In that light, the Court found no basis to interfere on the question of condonation of delay or the competence of the appellate authority to entertain the delayed appeal beyond the prescribed period.

Conclusion: No substantial question of law arose for consideration, and the appeal failed.

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