https://www.taxtmi.com/caselaws?id=780096 Limitation must be determined as a threshold issue before an appellate authority can examine the merits of a departmental appeal, because a time-barred appeal cannot be entertained on substance. The Revenue's challenge to the classification of imported goods was therefore not examined on merits, as the first appellate authority had not first decided the respondent's preliminary objection that the review and appeal were filed beyond the statutory period. The matter was remanded for a fresh decision on limitation alone, after hearing both sides, with no finding recorded on classification. en-us Wed, 15 Oct 2025 00:00:00 +0530 Sat, 18 Oct 2025 09:08:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780096 Limitation must be determined as a threshold issue before an appellate authority can examine the merits of a departmental appeal, because a time-barred appeal cannot be entertained on substance. The Revenue's challenge to the classification of imported goods was therefore not examined on merits, as the first appellate authority had not first decided the respondent's preliminary objection that the review and appeal were filed beyond the statutory period. The matter was remanded for a fresh decision on limitation alone, after hearing both sides, with no finding recorded on classification. Case-Laws Customs Wed, 15 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780096