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Issues:
1. Interpretation of the power of the Income-tax Appellate Tribunal to admit an appeal beyond the prescribed period of limitation under section 269G of the Income-tax Act. Analysis: The judgment of the Andhra Pradesh High Court dealt with a special appeal under section 269H of the Income-tax Act, focusing on whether the Income-tax Appellate Tribunal has the authority to admit an appeal filed beyond the limitation period specified in section 269G(1) of the Act. The case involved the acquisition of a rice mill by the appellant, who received a notice under section 269D(1) for undervaluation. Despite submitting objections, the property was acquired, and the appellant filed an appeal beyond the prescribed period. The Tribunal rejected the appeal, leading to the present special appeal. The crucial point of contention was the interpretation of section 269G(1) and its proviso, which outlines the timeline for filing an appeal against property acquisition orders. The proviso clearly states that the Appellate Tribunal may permit the appeal to be presented beyond the initial period if sufficient cause is shown before the expiry of the prescribed time. The court highlighted the distinction between section 253(5) and section 269G, emphasizing that the latter does not provide for the Tribunal to condone delays akin to section 5 of the Limitation Act. The judgment underscored that the specific provisions of section 269G govern the timeline for filing appeals in property acquisition cases under the Income-tax Act. The appellant argued for the application of section 5 of the Limitation Act through section 29(2) to enable the Tribunal to condone the delay. However, the court rejected this argument, citing Supreme Court precedents that limit the application of the Limitation Act to civil courts and not quasi-judicial tribunals. The judgment referenced a decision under the Andhra Pradesh Tenancy Act, affirming that the Limitation Act does not extend to tribunals unless expressly provided for by a special statute. Additionally, the appellant contended that allowing the Tribunal to condone delays would prevent injustice in various cases. However, the court held that such an interpretation would go against the clear language and intent of the statute. The judgment emphasized that Parliament deliberately crafted section 269G with a different provision from section 253(5), indicating a conscious departure in legislative intent. In conclusion, the Andhra Pradesh High Court dismissed the special appeal, upholding the Tribunal's decision to reject the appeal due to being time-barred. The court emphasized the importance of adhering to the specific provisions of section 269G for filing appeals in property acquisition cases under the Income-tax Act, without extending the application of the Limitation Act to quasi-judicial tribunals.
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