1991 (4) TMI 425

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..... 1956, read with section 20(1) of the Punjab General Sales Tax Act, 1948, was dismissed by the Deputy Excise and Taxation Commissioner, inter alia, holding the appeal being barred by time and there being extraordinary delay which has not been explained. 2.. Undisputedly no question with respect to the limitation was raised by the department when the appeal was filed in 1986. It is only at the sta .....

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..... ona fide belief that there was only one order. The petitioner has been under a bona fide belief prosecuting the remedy available against the said order. 3.. There is no mala fide attributed to the petitioner nor anything has been attributed to it that by this delay the petitioner would have gained anything. No motive for filing the appeal at belated stage had been attributed to the petitioner. .....

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