Appeal Dismissed for 91-Day Delay; Both Parties Must Follow Filing Deadlines Under Limitation Rules

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....The HC dismissed the appeal as time barred due to a 91-day delay in filing. The court held that the appellant/department, alleging lack of diligence by the respondent/assessee, must also adhere to the limitation period for filing appeals. The principle of equal diligence applies to both parties. The statute requires a fresh refund application following rectification of deficiencies. The court modified the Single Bench's direction, ordering the respondent to rectify all noted deficiencies and submit a fresh refund application within two weeks of receiving the order's certified copy. The appeal was therefore dismissed, and the matter was remanded for compliance with these conditions.....