https://www.taxtmi.com/caselaws?id=75409 Section 260A of the Income-tax Act prescribes a fixed limitation period for High Court appeals without conferring power to condone delay. In contrast, the Act expressly permits condonation for delayed appeals before the Commissioner (Appeals) and the Appellate Tribunal on sufficient cause. This legislative distinction supports exclusion of section 5 of the Limitation Act by necessary implication, as the Income-tax Act operates as a complete code for appellate forum, procedure and limitation. Order 41 Rule 3A of the Code of Civil Procedure is procedural and does not independently authorise condonation. Consequently, delay in filing a section 260A appeal cannot be condoned. en-us Wed, 28 Oct 2009 00:00:00 +0530 Wed, 14 Apr 2010 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75409 Section 260A of the Income-tax Act prescribes a fixed limitation period for High Court appeals without conferring power to condone delay. In contrast, the Act expressly permits condonation for delayed appeals before the Commissioner (Appeals) and the Appellate Tribunal on sufficient cause. This legislative distinction supports exclusion of section 5 of the Limitation Act by necessary implication, as the Income-tax Act operates as a complete code for appellate forum, procedure and limitation. Order 41 Rule 3A of the Code of Civil Procedure is procedural and does not independently authorise condonation. Consequently, delay in filing a section 260A appeal cannot be condoned. Case-Laws Income Tax Wed, 28 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75409