Strict limitation under tax law bars revision filed beyond the statutory outer limit despite administrative delay.

A tax case revision under the Tamil Nadu Value Added Tax Act was held not maintainable because it was filed beyond the prescribed ninety-day period and also beyond the further ninety-day condonable limit. The High Court applied the strict construction of limitation provisions in taxing statutes and held that, where the statute fixes an outer limit for delayed filing, the court cannot extend time on equitable or administrative grounds. The explanation that the file moved through the Commissioner's office did not amount to sufficient cause within the statutory scheme, and the revision was dismissed at the SR stage.

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Issues: Whether a tax case revision filed beyond the prescribed period and also beyond the further condonable period under Section 60(1) of the Tamil Nadu Value Added Tax Act, 2006 could be entertained on the ground of administrative delay and absence of willful default.

Analysis: The provision prescribed a limitation period of ninety days for filing the revision and empowered the High Court to admit a delayed petition only within a further period of ninety days upon being satisfied that sufficient cause existed. The petition was filed even after expiry of the extended period. The Court applied the settled principle that limitation provisions in taxing statutes must be construed strictly and that where the statute fixes a special period with a restricted extension, the Court cannot enlarge it on equitable or administrative grounds. The explanation that delay occurred because the file moved through the Commissioner's office did not cure the bar created by the statute.

Conclusion: The revision was not maintainable beyond the outer statutory limit and was dismissed at the SR stage.

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