Statutory limitation for appeals bars condonation beyond the outer limit, leaving time-barred fiscal appeals untenable.

A fiscal appeal must be filed within the statutory appeal period, and condonation is available only up to the express outer limit on sufficient cause being shown. Where the record shows service or dispatch of the order and the appeal is filed beyond that maximum period, the appellate authority has no jurisdiction to excuse the delay. The doctrine of sufficient cause cannot override a clear limitation bar in the statute, so a time-barred appeal filed after the condonable period cannot be entertained.

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Issues: Whether the appeal before the Commissioner (Appeals) was barred by limitation and whether delay beyond the statutory condonable period could be excused.

Analysis: The governing provision allowed filing of the appeal within two months from receipt of the order and permitted condonation only for a further period of one month on sufficient cause being shown. The record showed dispatch of the order by registered post and supported the finding that the appeal was filed well beyond the prescribed period. The Tribunal applied the settled principle that the appellate authority has no jurisdiction to condone delay beyond the statutorily permitted period, and that the doctrine of sufficient cause cannot override an express limitation bar.

Conclusion: The delay was not condonable and the dismissal of the appeal as time-barred was upheld, against the assessee and in favour of the Revenue.

Ratio Decidendi: Where a fiscal statute prescribes a fixed appeal period with a limited further period for condonation, the appellate authority cannot entertain an appeal filed beyond that outer limit.

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