Breaking SUPREME COURT REAFFIRMS PUBLIC DOMAIN PROTECTION FOR DIGITAL LAWS
New Delhi · Monday, 21 September 2026 9888666310 | [email protected]
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Supreme Court of India 2017-01-04 dismissed

Patel Brothers vs State of Assam and Ors

Bench: 2 — A.K. Sikri

In Brief

A tea dealer registered under GST and VAT Acts claimed sales tax exemption based on false information. After the exemption was reduced and penalties imposed, the dealer appealed through multiple stages. When filing a revision petition to the High Court under Section 81 of the VAT Act with a 335-day delay, the dealer sought condonation under Section 5 of the Limitation Act, 1963. The Supreme Court held that Section 5 is excluded by necessary implication from the VAT Act's scheme, as Section 84 specifically applies only Sections 4 and 12 of the Limitation Act. The Court rejected the argument that Section 29(2) of the Limitation Act applies, finding that the VAT Act is a complete code designed to ensure finality. The appeals were dismissed.

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Limitation Act Tax Law Administrative Law Statutory Interpretation

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