Limitation runs from the original duty adjudication, and later quantification does not restart the appeal period.

When an adjudication order itself determines duty liability and directs payment, limitation runs from receipt of that order. A later quantification of the exact amount by the Superintendent or Assistant Collector is only a ministerial arithmetical exercise and does not amount to a fresh adjudication or create a new starting point for filing an appeal. The appeal was therefore treated as time-barred because it was, in substance, directed against the original adjudication order, and the subsequent calculation could not extend the statutory limitation period.

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Issues: Whether the appeal before the Board was barred by limitation, and whether the later quantification of duty by the Superintendent extended the period of limitation.

Analysis: The limitation period had to be reckoned from the date on which the adjudication order was received by the appellant, since the order itself had already determined liability to duty and directed payment. The subsequent calculation of the exact amount by the Assistant Collector was only an arithmetical exercise based on the Collector's findings and did not amount to a fresh adjudication or a new order for purposes of limitation. The appeal filed before the Board was in substance against the Collector's order, and the later quantification could not postpone the statutory time limit.

Conclusion: The appeal to the Board was rightly treated as time-barred, and the dismissal of the appeal was sustained.

Ratio Decidendi: Where an adjudication order itself determines liability and directs payment, a later ministerial quantification of the amount does not create a fresh starting point for limitation.

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