1. The petitioner only asks for an opportunity to file a statutory appeal which, admittedly is beyond the period of statutory limitation under the Finance Act, 1994, under which services tax was levied (since subsumed with Goods and Service Tax).
2. Mr.Mohana Murali, learned Senior Panel Counsel, who accepts notice for R1, fairly does not object to the request as aforesaid. Hence the intervening delay is condoned.
3. The petitioner is granted three weeks from today to file an appeal as against the impugned order dated 28.09.2022. Appeal if filed within the period as aforesaid, shall be entertained by the receiving Registry without reference to limitation but ensuring compliance with all other statutory pre-conditions, including predeposit.
4. In light of the order passed as aforesaid, no notice is necessary to R2 and R3.
5. This writ petition is dismissed with liberty. No costs. Connected miscellaneous petition is closed.
