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TMI Blog2019 (1) TMI 1418X X X X Extracts X X X X X X X X Extracts X X X X ..... for the purpose of start point of period of limitation to file an appeal - Consequently and clearly the first appeal filed by the petitioner against the order dated 03.12.2018 was beyond the period for which delay may have been condoned, by about nine days - there is no error in the order of the appellate authority dismissing the appeal as time barred. Process amounting to manufacture or not - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitation. Clearly, no application for condonation of delay may have been entertained by the appellate authority beyond a period of thirty days from the date of expiry of normal period of limitation (three months). 3. In the instant case, there is also no dispute as to the date of the communication order passed by the Assessing Authority which may be relevant for the purpose of start point of pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... period of thirty days could not be condoned and it was clearly not maintainable by the appellate authority. 6. Consequently, there is no error in the order of the appellate authority dismissing the appeal as time barred. 7. Learned counsel for the petitioner then submitted that if the remedy of appeal is held to be non-existant, still jurisdiction of the writ Court against the original orde ..... X X X X Extracts X X X X X X X X Extracts X X X X
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