(1.) By way of this appeal, the appellant has challenged the judgment and order of the Tribunal whereby the Tribunal has disposed of the appeal of the appellant on the ground of limitation.
(2.) The appeal was admitted on 27-9-2016 on the following substantial question of law:-
(3.) He invited our attention to the observation made by the Commissioner vide order dated 30-11-2007 towards the fact that ample opportunities were granted to the appellant which reads as under:-