Limitation-based rejection of statutory appeals was set aside, with restoration allowed on additional tax payment.

Statutory appeals rejected as time-barred were restored after the delay was accepted as sufficiently explained, and the Court permitted revival on compliance with an additional tax payment over and above the amount already remitted. The challenge arose in the context of earlier contest to the assessment and related litigation on the underlying provision, but the operative point was that limitation alone had led to rejection. The Court therefore set aside the limitation-based rejection and directed restoration of the appeals on payment of the further sum ordered.

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Issues: Whether the orders rejecting the statutory appeals as time-barred were liable to be set aside and the appeals restored on compliance with further tax payment.

Analysis: The appeals were rejected solely on limitation, though the assessment proceedings had earlier been contested and the challenge to the relevant provision had travelled through prior litigation. The explanation for the delay in preferring the statutory appeals was accepted, and the Court considered it appropriate to permit restoration of the appeals on additional remittance of disputed tax, over and above the amount already paid.

Conclusion: The rejection of the appeals was set aside and restoration of the appeals was directed upon payment of the further amount ordered by the Court.

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