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    <description>Appeals were treated as within time because the Tribunal accepted the explanation that limitation ran from receipt of the communication seeking payment of penalty, so there was no delay in filing. The impugned order was also found to be conditional, and the party had not been given a proper opportunity before finalisation. The Tribunal therefore remanded the matter to the Commissioner for a fresh decision in accordance with law after providing an opportunity of hearing.</description>
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      <description>Appeals were treated as within time because the Tribunal accepted the explanation that limitation ran from receipt of the communication seeking payment of penalty, so there was no delay in filing. The impugned order was also found to be conditional, and the party had not been given a proper opportunity before finalisation. The Tribunal therefore remanded the matter to the Commissioner for a fresh decision in accordance with law after providing an opportunity of hearing.</description>
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