Statutory appeal limitation bars writ challenge where belated appeals were returned and time was not validly extended.

Writ jurisdiction under Article 226 cannot be used to sidestep a statutory appeal scheme under the Puducherry Value Added Tax Act, 2007, where appeals must be filed within thirty days and may be condoned only for a further thirty days on sufficient cause. Belated appeals that are returned and not pursued do not keep the challenge alive, and a writ filed after expiry of the outer limit cannot operate as an indirect extension of time. The assessment orders remained outside merits-based scrutiny through the statutory forum, and the writ petitions were held not maintainable.

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Issues: Whether writ petitions challenging assessment orders were maintainable after expiry of the statutory appeal period, where the belated appeals had been returned and were not pursued.

Analysis: The assessment orders were appealable under Section 47 of the Puducherry Value Added Tax Act, 2007, which prescribed a period of thirty days for appeal with a further thirty days on showing sufficient cause. The petitioner filed the writ petitions long after the outer limit had expired and without challenging the return of the belated appeals. The Court held that writ jurisdiction under Article 226 cannot be used to bypass a statutory limitation scheme or to obtain an indirect extension of time where the appellate authority has no power to condone delay beyond the prescribed period. The delay was treated as unreasonable, and the petitioner had lost the opportunity to seek merits-based scrutiny through the statutory forum.

Conclusion: The writ petitions were not maintainable and were liable to be dismissed.

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