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<h1>The Supreme Court dismissed the appeal in the case with citation 2016 (9) TMI 788 - SC.</h1> The Supreme Court dismissed the appeal in the case with citation 2016 (9) TMI 788 - SC. - 2016 (42) S.T.R. J274 (SC) Whether the writ petitioner, can challenge the order dated 31st December, 2012 passed by the Additional Commissioner in the writ jurisdiction on the ground of patent illegality and want of jurisdiction after expiry of the period of limitation prescribed in Section 85(3A) of the Finance Act, 1994 - High Court held that the provision stipulating the period of limitation under Section 85(3A) has to be strictly construed as any other interpretation would defeat the very object of enacting the said provision. - Apex Court dismissed the appeal The Supreme Court dismissed the appeal in the case with citation 2016 (9) TMI 788 - SC. Justices B. Lokur and R.K. Agrawal were involved in the order.