https://www.taxtmi.com/caselaws?id=8231 Section 5 of the Limitation Act, 1963 applies only to proceedings before a court, so it does not extend to the Income-tax Appellate Tribunal acting as a quasi-judicial body. In the absence of an express statutory provision, the Tribunal cannot condone delay in filing a time-limited reference application under the Income-tax Act, 1922. The statutory pattern in the tax enactments, which expressly authorised condonation in specific provisions, reinforced that no general power of condonation could be implied for such reference applications. en-us Tue, 03 Feb 1970 00:00:00 +0530 Mon, 06 Apr 2009 11:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8231 Section 5 of the Limitation Act, 1963 applies only to proceedings before a court, so it does not extend to the Income-tax Appellate Tribunal acting as a quasi-judicial body. In the absence of an express statutory provision, the Tribunal cannot condone delay in filing a time-limited reference application under the Income-tax Act, 1922. The statutory pattern in the tax enactments, which expressly authorised condonation in specific provisions, reinforced that no general power of condonation could be implied for such reference applications. Case-Laws Income Tax Tue, 03 Feb 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8231