Limitation runs from actual order receipt; timely appeal remitted for verification of supporting documentary evidence and fresh decision.

Limitation for filing an appeal was examined by reference to the actual receipt of the Order-in-Original. The appellant requested a copy of the order and received it by departmental email; despite an inconsistent order number and date in the email body, the request reference and attached order indicated a typographical error. The appeal was filed within the normal two-month period calculated from actual receipt. The matter was remitted to the Commissioner (Appeals) to verify the documentary evidence, including the adjudication order, and decide afresh.

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Issues: Whether the appeal before the Commissioner (Appeals) was filed within the prescribed limitation period, having regard to the date on which the Order-in-Original was actually received.

Analysis: The documentary evidence showed that the appellant had requested a copy of the Order-in-Original on 09.05.2024 and received the departmental email with the order attached on 21.05.2024. Although the email body contained an inconsistent order number and date, the reference to the appellant's request and the attached order established that the discrepancy was a typographical error. On that evidence, the appeal filed on 19.07.2024 was within the normal two-month period. Since the underlying documentary evidence and the correctness of the adjudication order required verification, the matter was remitted to the Commissioner (Appeals) for a considered decision.

Conclusion: The appeal was held to have been filed within the normal limitation period, and the matter was remanded to the Commissioner (Appeals) for verification of the documentary evidence and fresh decision.

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