https://www.taxtmi.com/caselaws?id=46297 An appeal filed before the Commissioner (Appeals) beyond the statutorily condonable period could not be treated as a merits-based appeal, so the doctrine of merger did not apply because the first appellate authority lacked jurisdiction to entertain it. Section 14 of the Limitation Act did not assist where the statutory appellate forum was not a court, and the Tribunal could not extend limitation by implication. On that basis, the Tribunal was justified in declining to examine the underlying dispute on merits and in holding that rectification proceedings could not be used to recall a validly passed order absent statutory power. en-us Fri, 21 Dec 2001 00:00:00 +0530 Sat, 17 Jul 2010 10:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=46297 An appeal filed before the Commissioner (Appeals) beyond the statutorily condonable period could not be treated as a merits-based appeal, so the doctrine of merger did not apply because the first appellate authority lacked jurisdiction to entertain it. Section 14 of the Limitation Act did not assist where the statutory appellate forum was not a court, and the Tribunal could not extend limitation by implication. On that basis, the Tribunal was justified in declining to examine the underlying dispute on merits and in holding that rectification proceedings could not be used to recall a validly passed order absent statutory power. Case-Laws Central Excise Fri, 21 Dec 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=46297