Statutory time limit for condonation cannot be extended beyond the prescribed maximum; a delayed appeal was rightly treated as time-barred.

The appellate scheme allows an appeal to the Commissioner (Appeals) within 60 days and permits condonation only for a further 30 days. Where the delay exceeds that maximum condonable period, the Commissioner (Appeals) has no power to extend time. On those facts, a delay of 180 days was beyond the statutory limit, so the appeal remained time-barred and the dismissal was upheld against the assessee.

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Issues: Whether the Commissioner (Appeals) could condone a delay of 180 days in filing the appeal beyond the statutory period.

Analysis: The appeal before the Commissioner (Appeals) was filed after a delay of 180 days. The statutory scheme permits filing within 60 days and empowers condonation only up to a further 30 days. The delay in the present case exceeded the maximum condonable period, and the settled legal position was that the appellate authority had no power to condone delay beyond the prescribed limit.

Conclusion: The delay could not be condoned and the dismissal of the appeal as time-barred was upheld, against the assessee.

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