Appellate for Advance Authority Ruling--—Limitation Period - The petitioner challenged an order dated 23.05.2022, passed by the AAAR whereby the petitioner’s appeal against an order dated 28.06.2019 passed by the AAR was rejected. The Appellate Authority had declined to entertain the petitioner’s appeal on the ground that it was barred by limitation. The court observed that there is no dispute that the order dated 28.06.2019, passed by AAR was promptly communicated to the petitioner. The petitioner claimed that the delay in filing the appeal is solely on the ground that the Appellate Authority was not constituted. The notification constituting the Appellate Authority was issued on 05.09.2019, however, the petitioner was not aware of the same at the material time. Ignorance of the notification cannot be a ground for extending the period of limitation. The delay is in excess of the period that could be condoned by the appellant. The court relied upon the decision in State of Goa v. Western Builders: (2006) 6 SCC 239 and Chhattisgarh State Electricity Board v. Central Electricity Regulatory Commission and Ors., wherein the Supreme Court had considered similar provisions and had held that given the language of the relevant provision limiting the period for which delay could be condoned, the period of limitation for filing the application / appeal could not be extended beyond the said period.

Held that:- The Hon’ble Court dismissed the writ petition.