Limitation under Insolvency Law bars late appeal beyond the statutory outer limit despite pending related proceedings.

An appeal under the Insolvency and Bankruptcy Code had to be filed within 30 days, with only a further 15 days available on sufficient cause; the outer statutory limit could not be crossed. Knowledge of the resolution plan approval was available to the appellant within time, yet the appeal was filed well after the maximum permissible period. Pending proceedings before the regulatory commission and the appellant's inability to quantify its claim were not a legal impediment and did not constitute sufficient cause for extending limitation. The appeal was therefore treated as time barred, and the Tribunal declined to examine the merits once limitation had expired.

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Issues: Whether the appeal under the Insolvency and Bankruptcy Code, 2016 was barred by limitation and whether delay beyond the statutory period could be condoned.

Analysis: The statutory scheme permits an appeal to be filed within 30 days, with a further condonable period not exceeding 15 days on sufficient cause being shown. The record showed that the appellant had knowledge of the approval of the resolution plan at least by 04.07.2019, while the appeal was filed much beyond the maximum permissible period. Pending proceedings before the Central Electricity Regulatory Commission and the appellant's asserted inability to quantify the claim were held not to constitute a legal impediment to filing the appeal within limitation. The Tribunal also noted that when jurisdiction is barred by limitation, it could not go into the merits of the challenge.

Conclusion: The appeal was held to be time barred and the request for condonation beyond the statutory limit was rejected.

Ratio Decidendi: Under section 61(2) of the Insolvency and Bankruptcy Code, 2016, an appeal cannot be entertained beyond the outer limit of limitation, and pendency of related proceedings or inability to quantify claims does not, by itself, amount to sufficient cause for extending that statutory period.

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