Closed limitation scheme bars further condonation for revenue appeals filed beyond the statutory outer limit.

The proviso to Section 36(1) of the Tamil Nadu General Sales Tax Act, 1959 creates a closed limitation scheme for revenue appeals, allowing condonation only within the further period expressly specified. Once the appeal is filed beyond that outer limit, the Appellate Tribunal has no jurisdiction to enlarge time by applying general limitation principles. On this reasoning, condonation of delay beyond the statutory cap was unsustainable, and the Tribunal's order permitting delay was liable to be set aside in favour of the assessee.

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Issues: Whether the Appellate Tribunal could condone the delay in filing the revenue appeal beyond the period permitted under Section 36(1) of the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The proviso to Section 36(1) permits condonation only within the further period specified therein, and the statute therefore creates a closed limitation scheme for appeals by the Government. Since the appeal was filed beyond the outer limit prescribed by the special statute, the Tribunal had no jurisdiction to enlarge time further. The general principles relating to limitation could not override the express statutory restriction governing the appeal.

Conclusion: The condonation of delay was unsustainable and the Tribunal's order allowing the delay was liable to be set aside, in favour of the assessee.

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