IBC Appeal Time Limits: 30-Day Period Extendable on Holiday, 15-Day Condonation Period Cannot Be Extended Under Section 61

NCLAT addressed the computation of limitation periods for filing appeals under IBC. The tribunal held that while the 30-day limitation period under Section 61 can be extended when the last day falls on a tribunal holiday (per Rule 3 of NCLAT Rules), the 15-day condonable period under Section 61(2) cannot be similarly extended. In this case, the appeal filed on 17.09.2024 was beyond both the 30-day limitation period (ending 30.08.2024) and the 15-day condonable period. Despite the appellant's organizational approval requirements constituting reasonable cause for delay, the appeal was dismissed as it exceeded the maximum condonable period. The ruling clarifies that Rule 3 of NCLAT Rules and Section 4 of Limitation Act cannot extend the statutory 15-day condonation limit. .....

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