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Issues: (i) Whether limitation for filing the appeal under Section 61 of the Insolvency and Bankruptcy Code, 2016 runs from the date of pronouncement of the impugned order or from the date of upload or knowledge of the order; (ii) Whether alleged technical glitches in the e-filing portal justify condonation of delay beyond the statutory period of 30 days plus 15 days.
Issue (i): Whether limitation for filing the appeal under Section 61 of the Insolvency and Bankruptcy Code, 2016 runs from the date of pronouncement of the impugned order or from the date of upload or knowledge of the order.
Analysis: The statutory scheme under Section 61(2) fixes limitation from the date of pronouncement of the order, with a further condonable period of not more than 15 days only on sufficient cause. The order was pronounced on 15.12.2025 and the appeal was filed on the 46th day. The Tribunal applied binding precedent holding that the clock for limitation under the IBC runs from the date of pronouncement and that subsequent knowledge or later upload does not arrest limitation.
Conclusion: The limitation period was held to commence from the date of pronouncement, and not from the date of upload or alleged knowledge.
Issue (ii): Whether alleged technical glitches in the e-filing portal justify condonation of delay beyond the statutory period of 30 days plus 15 days.
Analysis: The Tribunal accepted that technical difficulties in OTP delivery and portal functioning existed and that the appellant faced difficulty in filing the appeal on the last permissible day. However, it held that the IBC creates a strict outer limit for condonation and that neither hardship, equity, nor technical impediments can expand jurisdiction beyond the 30 plus 15 day limit. The Tribunal relied on precedent emphasizing that delay beyond the statutory ceiling is uncondonable.
Conclusion: The delay beyond the statutory outer limit could not be condoned.
Final Conclusion: The appeal was held to be time-barred beyond the maximum condonable period under the IBC, so the delay condonation application and the appeal both failed.
Ratio Decidendi: Under Section 61(2) of the Insolvency and Bankruptcy Code, 2016, limitation runs from the date of pronouncement and the Appellate Tribunal has no power to condone delay beyond the express statutory limit of 30 days plus 15 days, regardless of equitable or technical grounds.