Statutory condonation limit bars delayed Commissioner (Appeals) filings beyond the expressly permitted outer period.

An appeal filed before the Commissioner (Appeals) beyond the statutorily prescribed filing period and the expressly permitted further condonable period cannot be entertained. The appellate limitation scheme confines the authority's power to condone delay to that outer limit, while the general condonation power under Section 5 of the Limitation Act is excluded. As the undisputed delay fell outside the permitted condonable period, the appeal was barred by limitation, resulting in a finding against the assessee.

---

---

Issues: Whether an appeal filed before the Commissioner (Appeals) beyond the statutorily condonable period could be entertained.

Analysis: The appellate limitation scheme permits filing within the prescribed period and authorises condonation only for the further period expressly stipulated. The appellate authority has no power to condone delay beyond that outer limit, and the general power under Section 5 of the Limitation Act is excluded. The delay of 86 days beyond the normal filing period was undisputedly outside the condonable period.

Conclusion: The appeal before the Commissioner (Appeals) was barred by limitation and could not be entertained; the finding is against the assessee.

---