https://www.taxtmi.com/caselaws?id=797637 Section 85(3A) of the Finance Act, 1994 requires an appeal to the Commissioner (Appeals) within two months and permits condonation only for one further month. An appeal filed beyond that outer limit cannot be validated by an interim Tribunal order, hardship, sufficient cause, time spent obtaining departmental documents, a merits hearing, or reservation of orders, because none creates jurisdiction to extend the statutory period. Rectification is confined to patent, self-evident mistakes apparent from the record and cannot be used to review or reopen a concluded merits determination. Accordingly, rectification is unavailable where no such apparent error exists. en-us Fri, 21 Aug 2026 00:00:00 +0530 Wed, 26 Aug 2026 08:27:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797637 Section 85(3A) of the Finance Act, 1994 requires an appeal to the Commissioner (Appeals) within two months and permits condonation only for one further month. An appeal filed beyond that outer limit cannot be validated by an interim Tribunal order, hardship, sufficient cause, time spent obtaining departmental documents, a merits hearing, or reservation of orders, because none creates jurisdiction to extend the statutory period. Rectification is confined to patent, self-evident mistakes apparent from the record and cannot be used to review or reopen a concluded merits determination. Accordingly, rectification is unavailable where no such apparent error exists. Case-Laws Service Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797637