Limitation for appeal turns on receipt of a forwarding letter treated as a certified copy; delay condonation was refused.

A forwarding letter enclosing the order-in-original was treated as sufficient for limitation purposes, as it bore the characteristics of a certified copy for filing an appeal. The appellant had no acceptable basis to wait for any further certified copy, and the asserted oral advice of a former consultant was unsupported by material. The Tribunal treated this as an unjustified technical attempt to delay payment, applied the cited precedent as directly applicable, and rejected condonation of delay, holding the appeal time-barred.

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Issues: Whether the appeal was barred by limitation despite the appellant having received the order under a forwarding letter from the Assistant Collector and whether the delay, if any, deserved condonation.

Analysis: The order-in-original had been forwarded by the Assistant Collector and received by the appellant on 12 November 1994. That communication was treated as bearing the characteristics of a certified copy for the purpose of filing an appeal. The Tribunal found no acceptable basis for the appellant's insistence on waiting for some further certified copy, particularly when the plea of oral advice from a former consultant was unsupported by material. The conduct was viewed as a rigid and technical attempt to postpone payment and the reliance on the cited precedent was accepted as directly applicable.

Conclusion: The appeal was held to be time-barred and the request for condonation of delay was rejected.

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