When Delay Extinguishes Jurisdiction

The decision of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Allahabad in Purple Products Pvt. Ltd. v. Commissioner of Customs, Noida brings into sharp focus two often underestimated but structurally decisive aspects of tax adjudication namely, statutory limitation and procedural discipline. The ruling demonstrates how limitation provisions under Section 128 of the Customs Act operate as absolute jurisdictional bars, extinguishing appellate remedies once the maximum condonable period expires, irrespective of merits or hardship. The Tribunal’s refusal to entertain a post-pronouncement adjournment request underscores that procedural rules governing hearings and finality are not matters of convenience, but integral components of adjudicatory authority. J the App by JustIDT takes a quick look