Statutory limitation bars a delayed appeal where extension is not permitted; delay cannot be condoned by equity.

An appeal filed before the Commissioner (Appeals) after 1325 days was treated as barred by limitation under the special statutory scheme. The Court applied the settled principle that, where the statute fixes a limitation period and does not allow extension beyond it, equitable considerations cannot override the statutory bar. On that basis, the appellate challenge was held not maintainable, and the delay was not condoned. The Court also treated the time-barred challenge as incapable of being converted into a substantial question of law.

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Issues: Whether an appeal could be maintained when the underlying appellate remedy was pursued with an inordinate delay and whether such delay could be condoned under the special statutory scheme.

Analysis: The delay in filing the appeal before the Commissioner (Appeals) was held to be 1325 days. The Court followed the binding principle that, where a special statute prescribes a limitation period and the law does not permit extension beyond that period, equitable considerations cannot override the statutory bar. The Court also treated the issue as governed by the settled rule that the appellate forum is bound by the limitation framework and cannot treat such a time-barred challenge as giving rise to a substantial question of law.

Conclusion: The appeal was held to be not maintainable and the delay could not be condoned.

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