In Brief
The Supreme Court held that Section 5 of the Limitation Act, 1963 applies to revision petitions filed under Section 48 of the Himachal Pradesh Value Added Tax Act, 2005, allowing the High Court to condone delays beyond the prescribed 90-day period where sufficient cause is shown. The Court found no express exclusion of the Limitation Act in the VAT Act's text or scheme. Unlike the Assam VAT Act, which explicitly limits applicability to only certain Limitation Act sections, the Himachal Pradesh Act contains no such restriction. The presence of suo motu revisional powers and condonation provisions in appeal proceedings indicated legislative intent not to exclude Section 5. The cases were remitted to the High Court for merit-based review.
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