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Judgment
Heard Shri Bipin Garg, Cournsel for the appellants and Shri Govind Dixit, learned Departmental Representative for the respondent/Revenue.
Parties are agreed that the substantive appeals could be disposed of as they involve a short issue.
Shri Dixit submits that there is no merit in the appeals since these are preferred against orders of Commissioner (Appeals) rejecting assessee's
appeals on the ground that these were filed beyond the period of six months i.e. beyond the extended period of limitation and there was no power
conferred on the Commissioner to condone such delay. Shri Garg does not contest the correctness of this position, which is clear from the provisions
of Section 85(3) of the Finance Act, 1994 as well.
For the aforesaid reasons, the appeals are dismissed and the respective orders passed by the learned Commissioner's (Appeals), which are the
subject matter of challenge in each of the appeals, are upheld. No costs.
(Dictated and pronounced in open court)