The Law of Limitation, 1963 is a crucial procedural statute that determines the timeframe within which legal rights can be enforced. It does not confer any new rights but regulates the period for asserting existing ones. In a legal system driven by certainty, efficiency, and fairness, the law of limitation plays a foundational role. It prevents the resurrection of stale claims and promotes timely redressal of grievances. This becomes particularly important in the domain of income tax, where assessments, appeals, and revisions are all subject to strict timelines.
Legal frameworks require not only clarity in substantive rights and obligations but also definitive timelines within which such rights must be asserted. These timelines ensure administrative efficiency, reduce litigation backlog, and promote prompt action by stakeholders. However, where a statutory timeline is not adhered to, procedural law may result in dismissal of claims. It is in this tension between substantive justice and procedural compliance that Section 14 of the Limitation Act finds its significance.
The Principle Behind Section 14
Section 14 of the Limitation Act permits the exclusion of time spent in pursuing civil proceedings in a forum that ultimately proves to be incompetent due to lack of jurisdiction. This provision serves to ensure that the spirit of justice prevails over procedural barriers. While the law encourages diligence, it also recognizes human error in navigating complex legal procedures. The idea is not to punish a bona fide litigant for filing a claim in the wrong forum, but to provide a remedy where actions have been undertaken in good faith.
Essential Ingredients of Section 14
To invoke the benefit of Section 14, certain conditions must be satisfied:
- The litigant must have been pursuing another civil proceeding.
- The earlier proceeding must have been prosecuted with due diligence.
- The litigant must have acted in good faith.
- The forum that entertained the earlier proceeding must have been unable to entertain it due to a defect in jurisdiction or similar reason.
It is not necessary that the earlier proceeding be initiated with flawless legal understanding. The emphasis is on the honesty of purpose and the genuine intent to seek remedy.
Application in Income Tax Matters
Income tax proceedings involve various stages and forums including the Assessing Officer, the Commissioner (Appeals), the Income Tax Appellate Tribunal, High Courts, and the Supreme Court. Each of these stages has its own time limits for filing appeals or petitions. Misinterpretation or confusion about jurisdiction or applicable procedure may lead a taxpayer to pursue a remedy in the wrong forum.
For instance, an assessee may file a writ petition directly before the High Court against a reassessment notice, only to be directed to approach the Commissioner (Appeals) first. If the time consumed in the High Court proceeding is not excluded, the appeal before the Commissioner may be time-barred. Here, Section 14 of the Limitation Act can offer relief by excluding the duration spent before the incorrect forum while computing the limitation period.
Judicial Attitudes Towards Section 14
Judicial interpretations have progressively embraced a liberal approach toward the application of Section 14. Courts have emphasized that procedural rules should aid, and not obstruct, the path to justice. The Supreme Court and various High Courts have upheld the idea that the benefit of Section 14 should not be denied on hyper-technical grounds. This approach is particularly relevant in income tax cases, which often involve interpretational complexity and procedural intricacies.
For example, in a case where a taxpayer mistakenly files an appeal before a tribunal that lacks jurisdiction, and subsequently approaches the correct appellate forum, courts have allowed exclusion of the time spent in the earlier proceedings. The ruling is often conditioned upon the demonstration of good faith and due diligence.
Nature of Bona Fide Prosecution
One of the most contested aspects in the application of Section 14 is whether the earlier proceeding was prosecuted with bona fide intent. The court scrutinizes the conduct of the litigant, looking for signs of due care and genuine belief that the chosen forum had jurisdiction. Mere ignorance of law is not excused unless accompanied by reasonable effort to ascertain the correct legal course.
The burden of proof lies on the litigant to show that the earlier proceeding was not frivolous or speculative. For income tax cases, this often includes demonstrating that the legal position was debatable or unclear, and that the litigant took timely action upon learning of the jurisdictional defect.
Legislative Compatibility with Income-tax Act
While the Income-tax Act, 1961 contains its own procedural framework, it does not explicitly bar the application of the Limitation Act. Therefore, courts have interpreted that general principles of limitation, including Section 14, can apply to income tax matters in appropriate circumstances. The compatibility is established on the understanding that the Income-tax Act is silent on the exclusion of time spent in proceedings before incompetent forums.
However, Section 14 does not automatically override the timelines prescribed in the Income-tax Act. It acts as a judicial aid and is invoked only when procedural fairness and equity demand so. Each case is decided on its facts, and the relief under Section 14 is not granted mechanically.
Complexities in Forum Navigation
Navigating the procedural hierarchy in income tax proceedings can be challenging, especially when multiple forums appear to have overlapping jurisdiction. Issues such as whether a writ petition should be filed first or whether statutory appeal must be exhausted can create confusion. This procedural maze may inadvertently result in delayed or misfiled actions.
Section 14 acts as a safety net in these cases, provided the taxpayer has acted without malice and within a reasonable understanding of the law. By excluding the time spent in bona fide proceedings before an incompetent forum, it prevents miscarriage of justice due to technicalities.
Interplay with Section 5 of the Limitation Act
While Section 14 excludes time spent in earlier proceedings, Section 5 of the Limitation Act allows for condonation of delay upon showing sufficient cause. These provisions are sometimes invoked together in income tax cases. For instance, if a taxpayer misses a limitation deadline and also needs exclusion of time due to an earlier proceeding, both sections may be relied upon simultaneously.
The key distinction is that Section 5 applies to condoning delay in filing, whereas Section 14 deals with exclusion of time. Courts often examine the overall conduct and timeline to assess whether both provisions can be harmoniously applied.
Public Policy Considerations
The underlying public policy of the Limitation Act is to promote certainty and avoid indefinite litigation. However, rigid enforcement of limitations can lead to injustice in deserving cases. Section 14 is the legislative mechanism to ensure that this does not happen.
In income tax matters, this public policy objective aligns with the need to resolve tax disputes fairly and efficiently. By allowing time exclusion in bona fide jurisdictional errors, the statute encourages responsible litigation and discourages arbitrary penalties for honest mistakes.
Illustrative Case Example
Consider an assessee who files a writ petition before the High Court to challenge an assessment order, believing it involves a constitutional issue. The High Court later rules that the proper remedy was an appeal before the Commissioner (Appeals). If the assessee then promptly files such an appeal, Section 14 can be used to exclude the time consumed before the High Court from the limitation period.
Such an approach ensures that the taxpayer’s access to appellate remedy is preserved and not extinguished by a technical oversight. It promotes the integrity of the appellate process and upholds the taxpayer’s right to be heard.
Importance of Legal Advice and Diligence
Despite the availability of Section 14, reliance on this provision should not be seen as a substitute for proper legal advice. Taxpayers are expected to exercise diligence in identifying the correct appellate forum. Legal counsel plays a vital role in guiding taxpayers through complex procedural requirements.
Nonetheless, Section 14 serves as an important judicial tool when a litigant, despite acting responsibly, finds themselves before an incompetent forum due to reasonable error. The courts weigh the nature of the legal issue, the clarity of jurisdictional provisions, and the timeliness of corrective action.
Role of Legal Precedents
The Indian judiciary has developed a body of case law that governs the application of Section 14 in income tax matters. These precedents offer guiding principles on aspects such as what constitutes good faith, how due diligence is assessed, and what qualifies as a defect of jurisdiction. Each judgment contributes to refining the scope of the provision and adapting it to the realities of tax litigation.
As legal interpretations evolve, so does the scope of procedural relief under the Limitation Act. This dynamic nature enables the courts to respond to changing legal complexities while preserving fundamental principles of justice.
Need for Clear Legislative Guidelines
Given the increasing reliance on Section 14 in tax disputes, there is a case for providing clearer legislative guidance on its applicability to income tax proceedings. Clarification on the permissible extent of time exclusion, format for invoking such relief, and interaction with statutory timelines would reduce litigation and enhance procedural consistency.
Until then, courts continue to apply the provision based on equity, facts, and legal reasoning. The responsibility lies equally on litigants and legal advisors to ensure that this provision is not misused.
Introduction to Judicial Interpretation
The effectiveness of any statutory provision lies not just in its text but in how courts interpret and apply it in real-life disputes. Section 14 of the Limitation Act has received considerable attention from Indian courts, which have, over the years, clarified its scope, applicability, and limitations. In the domain of income tax proceedings, the application of Section 14 has grown in significance due to the frequent occurrence of jurisdictional missteps and the complexities inherent in tax litigation.
We explore a range of judicial pronouncements where courts have either allowed or rejected the benefit of Section 14 to litigants engaged in income tax disputes. These rulings help form a consistent legal framework and demonstrate the conditions under which courts lean towards a liberal or a strict approach.
The Foundation Case: Roshanlal v. R.B. Mohan Singh
One of the early landmark decisions that laid the groundwork for understanding Section 14 was Roshanlal v. R.B. Mohan Singh. Though not a tax case, the Supreme Court emphasized that Section 14 should be interpreted liberally to advance the cause of justice. The court held that the section is designed to mitigate hardship and should not be construed narrowly or restrictively. This case has served as a touchstone in many later rulings, including those in income tax matters.
Supreme Court Decision in Consolidated Engineering Enterprises v. Principal Secretary
In this notable case, the apex court reiterated the scope of Section 14 by allowing time exclusion where a litigant had initiated proceedings before the wrong forum due to jurisdictional uncertainty. While this case pertained to arbitration, the principles were adopted by income tax tribunals and high courts dealing with similar factual matrices. The court stressed that the essential test is whether the litigant acted with due diligence and in good faith, even if the choice of forum turned out to be legally incorrect.
Commissioner of Income Tax v. Indian Farmers Fertilizer Cooperative Limited
This case brought Section 14 squarely into the domain of income tax. Here, the assessee had first approached the High Court through a writ petition against a demand notice. The court directed the assessee to first exhaust the alternate statutory remedy by approaching the Commissioner (Appeals). The assessee complied and later requested that the period spent in High Court proceedings be excluded under Section 14.
The Income Tax Appellate Tribunal and subsequently the High Court accepted the plea. It was observed that the assessee had not been negligent but was seeking a remedy in a forum based on their interpretation of law. The courts recognized that the litigant’s action was bona fide and that the time exclusion under Section 14 was appropriate.
High Court Decision: Kalpataru Power Transmission Ltd. v. Deputy Commissioner of Income Tax
In this case, the Gujarat High Court evaluated the conduct of the assessee who had initially filed an appeal before an incorrect appellate authority. Upon realization, the assessee withdrew the appeal and filed before the correct forum. The delay in filing was covered by invoking Section 14.
The court emphasized that the guiding principle is not perfection in procedural choices but honesty of intention and a diligent pursuit of remedies. The court reiterated that Section 14 is meant to cushion litigants from being penalized for honest errors.
Limitation of Relief: CIT v. Woodward Governor India Pvt. Ltd.
This case is significant for marking the boundaries of Section 14. The court in this instance did not permit exclusion of time under Section 14, as it found that the assessee had acted in a negligent and indifferent manner. The appeal had been filed without proper jurisdictional basis, and there was no effort to rectify the error in a timely fashion.
This decision reinforced the requirement that Section 14 relief is conditional. It cannot be claimed as a matter of right. The burden lies squarely on the litigant to demonstrate good faith and due diligence. Absent these elements, the procedural lapses are not condoned.
Procedural Complexity and Honest Mistakes
Income tax matters often involve parallel remedies such as revision under section 264, rectification under section 154, or appeal under section 246A. Taxpayers may initially choose the wrong course due to unclear facts or multiple interpretational possibilities. The courts have generally been empathetic to such errors when they are coupled with prompt corrective action.
In many decisions, courts have acknowledged that the intricacy of the income tax statute often leads to uncertainty about the appropriate remedy. However, this leniency is only extended when the mistake is accompanied by a transparent and timely effort to rectify it.
Coordination Between Forums and Delay Justification
The role of coordination between various forums also plays into judicial reasoning. For instance, if a higher court suggests withdrawing a case and pursuing an alternative remedy, the time consumed in that suggestion is often protected under Section 14. Courts view such action as implicit approval of the bona fide nature of the earlier proceeding.
Further, when courts entertain the matter, issue notices, or hear preliminary arguments before eventually dismissing it on jurisdictional grounds, such conduct by the court itself supports the taxpayer’s bona fides. It confirms that even the judiciary did not immediately find the forum inappropriate.
Procedural Rights and Substantive Justice
The theme that resonates across judicial decisions is the commitment to substantive justice over procedural rigidity. Courts have emphasized that procedural rules are a means to an end and should not obstruct the fair adjudication of rights. This philosophy directly supports the invocation of Section 14 when the litigant’s intentions are fair and the conduct is responsible.
Income tax litigation often determines substantial financial liabilities. Denying a hearing due to a technical misstep would amount to undermining the taxpayer’s substantive rights. Therefore, procedural provisions like Section 14 are essential to ensure equitable treatment.
Comparative Analysis with Other Jurisdictions
While this article focuses on Indian jurisprudence, it is relevant to note that comparable legal systems have similar safeguards. In many common law jurisdictions, courts apply equitable doctrines to prevent hardship caused by procedural mistakes. These comparative standards further validate the Indian approach of liberal interpretation.
Foreign precedents, though not binding, are often cited to illustrate the universal principle that justice must prevail over technical errors. Indian courts have increasingly drawn upon these to bolster their interpretations.
Impact on Revenue Authorities
From the revenue authority’s perspective, Section 14 may appear to disrupt administrative certainty. It introduces a degree of flexibility in interpreting limitation periods. However, the provision is applied with sufficient judicial scrutiny to ensure that it does not become a tool for delay or abuse.
Revenue departments have contested Section 14 claims by challenging the bona fides of taxpayers and highlighting procedural negligence. Courts have responded by carefully weighing facts and applying strict thresholds before granting relief.
Balancing Equity and Timeliness
The essence of Section 14 is balance. It seeks to harmonize the need for finality in litigation with the equally important need to protect genuine litigants. The courts’ approach reflects this balancing act, providing relief where merited but declining it where the litigant’s conduct is casual or lacks diligence.
Judicial decisions reiterate that while law must be certain, it must also be just. Section 14 exemplifies this dual objective. Its discretionary nature allows courts to evaluate the full context and arrive at a fair conclusion.
Importance of Documentation and Timelines
One recurring theme in judicial scrutiny of Section 14 applications is the importance of accurate records. Litigants must maintain comprehensive documentation to demonstrate the timeline of events, forum transitions, and efforts undertaken to comply with legal requirements.
Properly documented pleadings, withdrawal applications, and communications with forums strengthen the case for time exclusion. Courts rely on such evidence to establish bona fides and determine the extent of exclusion warranted.
Parting Thoughts on Case Law Trends
Judicial precedent on Section 14 shows an evolving and maturing legal framework that recognizes the realities of modern litigation, especially in technical areas like income tax. The trend favors relief where the intent is sincere, and procedural missteps are not the result of indifference or manipulation.
As tax litigation continues to grow in volume and complexity, the jurisprudential relevance of Section 14 will expand. Understanding these precedents is crucial for taxpayers, legal practitioners, and adjudicating authorities alike.
Interplay with Income Tax Jurisprudence
The Income-tax Act, 1961 is a self-contained code, yet it often interacts with principles and provisions found in general procedural law, such as the Limitation Act, 1963. While the applicability of the Limitation Act to income tax matters is not always automatic, courts have held that certain equitable provisions—particularly Section 14—can be invoked where procedural justice is involved. Section 14 deals with the exclusion of time spent in bona fide proceedings in a court without jurisdiction.
Judicial interpretations have consistently leaned on the principle that procedural rigour must not defeat substantive justice. The invocation of Section 14 in tax litigation depends on the unique factual matrix of each case, especially where a taxpayer or the Department has pursued a remedy in a forum ultimately found to lack jurisdiction. In such cases, the benefit of Section 14 may be extended to prevent the dismissal of an appeal or claim on technical limitation grounds.
From Stringent to Equitable Interpretations
Historically, tax authorities and some tribunals took a strict approach, maintaining that the Limitation Act did not apply to income tax proceedings due to the presence of explicit time frames within the Income-tax Act itself. However, as tax litigation became more complex and multi-tiered, this rigid approach often led to situations where genuine litigants were penalised despite acting in good faith.
Courts began to realise that such strict construction undermined the fundamental objectives of justice. Consequently, judicial pronouncements started moving towards an equitable interpretation, invoking Section 14 in instances of mistaken jurisdiction, whether by the taxpayer or the Revenue Department. This shift acknowledges the realities of navigating multiple appellate forums and the inherent ambiguity that can sometimes cloud jurisdictional determinations.
The Cornerstone of Section 14 Relief
The concept of bona fide action is central to the application of Section 14. It is not enough for a party to have approached the wrong forum; the action must have been taken honestly, in good faith, and with due diligence. In other words, the litigant should not have intended to delay the proceedings or mislead the judicial process.
Income tax proceedings involve several appellate layers, including the Commissioner (Appeals), Income Tax Appellate Tribunal (ITAT), High Court, and the Supreme Court. Mistakes in approaching the correct forum—particularly in cases involving mixed questions of law and fact—are not uncommon. Courts have thus repeatedly held that if the taxpayer can demonstrate a bona fide belief in the jurisdiction of the original forum, the delay caused thereby can be condoned under Section 14.
Key Case Laws Illustrating Section 14’s Application in Income Tax Context
Commissioner of Income Tax v. Lakshmi Lines Ltd.
In this landmark decision, the Supreme Court laid down that Section 14 could be invoked in cases where a party prosecuted proceedings in good faith before a forum that ultimately lacked jurisdiction. The Court emphasised that procedural laws are designed to further the cause of justice, not frustrate it. The decision is frequently cited in income tax matters, especially where the taxpayer has taken diligent steps but chosen the wrong appellate route.
Kalpataru Power Transmission Ltd. v. DCIT
This High Court ruling accepted the plea of the taxpayer who had filed an appeal before the wrong forum due to a misreading of jurisdictional provisions. The Court held that the time spent in such proceedings would be excluded under Section 14, provided the taxpayer had acted in good faith and with due diligence. This case reaffirmed the judiciary’s commitment to balancing procedural requirements with equitable justice.
CIT v. Asia Power Projects Ltd.
Here, the issue revolved around the delay in filing an appeal due to earlier litigation in a forum later deemed incompetent. The court allowed the exclusion of time under Section 14, reiterating that litigants should not suffer due to complexities in legal procedure, especially when acting upon professional advice and with no intention to misuse the process.
Application in Departmental Proceedings and Recovery Litigation
It is not only the taxpayer who may benefit from Section 14. The tax authorities themselves sometimes face jurisdictional uncertainties. For example, in recovery proceedings under Sections 226 or 222 of the Income-tax Act, if the Revenue first takes steps under one statutory provision only to later realise that an alternative route was required, the time spent may be protected under Section 14.
This reflects the principle that equity must be available to both parties in a dispute. Courts have considered such protection valid, as long as there was no negligence, mala fide intention, or undue delay on the part of the Department.
Procedural Hurdles and Section 14’s Role in Appeals Before ITAT and High Courts
Where a taxpayer files an appeal before the ITAT which is later returned due to lack of jurisdiction, and the correct forum is the Commissioner (Appeals) or High Court, the time lost in the interim may be excluded under Section 14. However, procedural compliance in terms of limitation must still be closely examined.
Similarly, when High Courts reject petitions due to lack of jurisdiction and advise the assessee to approach the ITAT or vice versa, courts have, in subsequent cases, excluded the time spent in wrong proceedings. Section 14 thus emerges as a tool that ensures that genuine litigants do not lose the right to appeal due to honest jurisdictional confusion.
Limitations and Challenges in Applying Section 14 in Income Tax Cases
Tax Code as a Complete Code
One major hurdle in applying Section 14 is the often-asserted view that the Income-tax Act is a complete code in itself. It contains specific limitation periods, appeal processes, and remedies. As a result, courts and tribunals have been cautious about permitting general procedural statutes like the Limitation Act to override specific tax provisions.
However, this view is moderated by the principle that in the absence of explicit prohibition, beneficial provisions from general law can be read into tax law to serve justice.
Distinction Between Procedural Lapse and Jurisdictional Error
Another important limitation lies in distinguishing between a procedural lapse and a jurisdictional mistake. Section 14 only applies where the previous proceedings were instituted in a court or tribunal lacking jurisdiction. If the delay arose due to negligence or failure to act in time, Section 14 would not apply.
For instance, filing an appeal with the correct authority but beyond the time limit due to oversight cannot be excused under Section 14. The provision strictly applies to jurisdictional missteps, not delays born of administrative error or casual inattention.
Requirement of Diligence and Good Faith – Evidentiary Burden
The burden of proof under Section 14 lies on the party seeking exclusion of time. In income tax matters, this means the taxpayer must provide credible evidence of diligence, such as legal opinions obtained, timeline of actions taken, and explanations for each procedural step.
This often becomes a challenging requirement, especially in high-stake corporate tax litigations, where multiple advisors and legal teams may be involved. Courts will scrutinise whether the taxpayer acted swiftly upon realising the error, whether steps were taken to correct the course of litigation, and whether the overall conduct reflected a bona fide approach.
Implications for Tax Professionals and Assessing Officers
Greater Emphasis on Forum Selection and Legal Advice
The increased reliance on equitable principles such as Section 14 puts a higher onus on tax professionals and consultants. Accurate forum selection, correct advice regarding jurisdiction, and timely filing of appeals are now more critical than ever. Misjudgment in these areas can expose clients to limitation risks, requiring resort to Section 14 and attendant evidentiary burdens.
Professionals must document their advice, communicate jurisdictional risks clearly, and follow up on procedural compliance. This is particularly important in transitional tax cases, such as those involving legacy laws, merged forums, or overlapping regulatory regimes.
Assessing Officers and Judicial Discipline
From the Department’s perspective, assessing officers and appellate authorities must also appreciate the judicial trend favouring equitable treatment. Denying relief solely on limitation grounds when jurisdictional confusion is evident may not withstand scrutiny before higher forums.
Training and circulars issued by the Board can incorporate guidelines on recognising bona fide litigation and conceding exclusion of time where justified. This will promote judicial economy and reduce avoidable litigation.
Sectoral Impacts and Relevance in Contemporary Tax Landscape
GST Transition Cases and Section 14 Analogies
With the introduction of GST and the subsuming of multiple indirect taxes, several litigants found themselves caught in jurisdictional overlaps during transition. Though the GST law has its own timelines, the principle of excluding time spent in bona fide proceedings in wrong forums has been considered in judicial discussions.
Section 14, while directly applicable to limitation under civil law, serves as an interpretative aid in such transitional taxation matters as well. The underlying philosophy of procedural fairness and reasonable cause is universal, and courts have often drawn from the spirit of Section 14 to permit continuation of claims or proceedings.
International Taxation and Cross-Border Dispute Resolution
In cross-border tax disputes involving multiple jurisdictions and mutual agreement procedures, issues of forum shopping and mistaken recourse to wrong mechanisms are not uncommon. Where Indian taxpayers pursue remedies in jurisdictions that later deny authority to adjudicate, Section 14 may be considered while evaluating time-barred appeals under domestic law.
This has implications for the increasingly internationalised tax administration framework. Taxpayers involved in transfer pricing, equalisation levy, and other digital economy tax matters may be more prone to forum confusion, and Section 14’s equitable mechanism provides necessary protection in genuine cases.
Conclusion
The applicability of Section 14 of the Limitation Act, 1963, in income tax proceedings underscores the judiciary’s emphasis on balancing procedural rigour with substantive justice. While the law of limitation is grounded in the principle that litigation must not continue indefinitely, Section 14 serves as a necessary safeguard to prevent unjust consequences arising from technical errors or bona fide procedural missteps. Its provision for excluding the time spent litigating in a wrong forum when pursued with due diligence and good faith reflects a nuanced understanding that access to justice must not be derailed by mere technicalities.
In the context of income tax proceedings, where statutes such as the Income-tax Act, 1961, lay down strict timelines for appeals, revisions, and other actions, the invocation of Section 14 becomes both delicate and significant. Courts and tribunals have, through various decisions, extended the protective scope of this section to ensure that genuine litigants are not prejudiced for having acted in good faith. At the same time, they have drawn clear lines to discourage abuse or negligence. The principles laid down in landmark judgments, both by the Supreme Court and High Courts, reveal a consistent judicial intent to interpret procedural laws in a manner that furthers justice rather than obstructs it.
However, it must be remembered that the application of Section 14 is not automatic. The taxpayer must convincingly establish that the prior proceeding was pursued in good faith, before a court or authority with bona fide belief in its jurisdiction, and that the matter was dismissed on grounds of lack of jurisdiction or a similar defect. It places a significant burden on the assessee to satisfy these threshold requirements.
Overall, Section 14 continues to be a valuable instrument in mitigating the rigidities of procedural law, particularly in tax litigation, where complex jurisdictional and interpretational issues often lead taxpayers to alternate forums. By allowing the exclusion of time lost in such bona fide missteps, it ensures that the right to be heard is preserved and that the taxpayer’s entitlement to substantive relief is not sacrificed at the altar of procedural rigidity. This nuanced application of limitation law reinforces the broader goals of equity and justice within the Indian legal system.