https://www.taxtmi.com/caselaws?id=22181 Section 12(4) of the SAFEMA sets a mandatory appeal period of forty-five days from service, with condonation available only up to a sixty-day outer limit on sufficient cause. The Karnataka HC held that the Appellate Tribunal had no jurisdiction to extend limitation beyond that statutory maximum, so an appeal filed after sixty days was time-barred. Section 14 of the Limitation Act was inapplicable because the matter had not been pursued before another competent forum, and Section 5 could not override the special statute's express limit. The omission to mention the appellate forum in the order did not enlarge the prescribed period. en-us Mon, 08 Jul 1991 00:00:00 +0530 Mon, 07 Dec 2009 18:15:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22181 Section 12(4) of the SAFEMA sets a mandatory appeal period of forty-five days from service, with condonation available only up to a sixty-day outer limit on sufficient cause. The Karnataka HC held that the Appellate Tribunal had no jurisdiction to extend limitation beyond that statutory maximum, so an appeal filed after sixty days was time-barred. Section 14 of the Limitation Act was inapplicable because the matter had not been pursued before another competent forum, and Section 5 could not override the special statute's express limit. The omission to mention the appellate forum in the order did not enlarge the prescribed period. Case-Laws Income Tax Mon, 08 Jul 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22181