(1.) Feeling aggrieved and dissatisfied with the impugned order passed by the learned Customs, Excise and Service Tax Appellate Tribunal, West Zonal Bench, Ahmedabad (hereinafter referred to as "the learned Tribunal"), dated 17-4-2012 in application No. E/S/308/2011 [2012 (286) E.L.T. 431 (Tri. - Ahmd)] by which the learned tribunal has rejected the application for condonation of delay in preferring the appeal and consequently has rejected the appeal and the stay application in the appeal, the assessee has preferred the present Tax appeal to consider the following substantial question of law :
(2.) The facts leading to the present Tax Appeal in nutshell are as under :
(3.) Shri D.K. Trivedi, learned advocate appearing on behalf of the appellant has vehemently submitted that in the facts and circumstances of the case the learned Tribunal has materially erred in not condoning the delay and consequently rejecting the appeal on the ground of limitation.