Limitation Act condonation applies to VAT revision proceedings absent express or implied exclusion under the special statute.

Section 5 of the Limitation Act, 1963 applies to revision proceedings under the Himachal Pradesh Value Added Tax Act, 2005 because Section 48 prescribes a 90-day limitation period but does not expressly exclude the Limitation Act. Applying Section 29(2), Sections 4 to 24 govern a special law unless excluded expressly or by necessary implication. The Act's scheme, including condonation power in other provisions, showed no such exclusion, so delay in filing the revision could be condoned.

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Issues: Whether the High Court could condone delay in filing a revision under Section 48 of the Himachal Pradesh Value Added Tax Act, 2005 by applying Section 5 of the Limitation Act, 1963 in the absence of an express exclusion.

Analysis: Section 48 of the Himachal Pradesh Value Added Tax Act, 2005 prescribes a 90-day period for revision to the High Court but does not expressly exclude the Limitation Act. Under Section 29(2) of the Limitation Act, 1963, the provisions in Sections 4 to 24 apply to a special law unless expressly excluded. The statutory scheme of the Himachal Pradesh Value Added Tax Act, 2005, including the absence of an exclusion clause in Section 48 and the presence of condonation power in other provisions of the Act, did not indicate either express or necessary implied exclusion of Section 5. The authorities relied upon for exclusion were distinguished on the basis of materially different statutory schemes.

Conclusion: Section 5 of the Limitation Act, 1963 applies to revision proceedings under Section 48 of the Himachal Pradesh Value Added Tax Act, 2005, and the delay could be condoned.

Ratio Decidendi: In a special law prescribing a distinct limitation period, Section 5 of the Limitation Act, 1963 applies unless the special law expressly or by necessary implication excludes it.

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