JUDGMENT : S. Manikumar, J. 1. Tax Case Revision Petition SR.No.87191 of 2005 has been filed against the order, made in S.T.A.No.221 of 2001, on the file of the Tamil Nadu Sales Tax Appellate Tribunal (Additional Bench), Chennai, with a delay of 91 days. 2. Reasons assigned for condonation are that the date of receipt of the order was on 21/2/2003. The file was circulated to the Law Officer on 20/8/2003. After getting opinion, papers were sent for filing on 21/8/2003. Last date for filing the Tax Case fell on 22/5/2003. But the Tax Case came to be filed only on 21/8/2003, resulting in a delay of 91 days. Delay has occurred due to the process of getting opinion from the Commissioner’s Office. Delay has occurred solely due to the above said administrative reasons, and not willful. 3. Heard Mr. V. Hari Babu, Additional Government Pleader (Taxes) appearing for the petitioner and perused the materials available on record. 4. Section 60 (1) of the Tamil Nadu Value Added Tax Act, 2006, reads as follows:- Revision by High Court - (1) Within ninety days from the date on which the order under sub-section (4) (5) or (7) of Section 58 is served, any person who objects to such order of the Joint Commissioner may prefer a petition to the High Court on the ground that the Appellate Tribunal has either decided erroneously or failed to decide any question of law:- Provided that the High Court may, within a further period of ninety days, admit a petition preferred after the expiration of the first mentioned period of ninety days aforesaid if it is satisfied, that the petitioner had sufficient cause for not preferring the petition within the first mentioned period.” 5. While interpreting the taxing statute, in Sales Tax Commissioner Vs. Modi Sugar Mills { AIR 1961 SC 1047 }, the Hon'ble Supreme Court observed thus :- “In interpreting a taxing statute, equitable considerations are entirely out of place. Nor can taxing statutes be interpreted on any presumptions or assumptions. The Court must look squarely at the words of the statute and interpret them. It must interpret a taxing statute in the light of what is clearly expressed: It cannot imply anything which is not expressed; it cannot import provisions in the statutes so as to supply any assumed deficiency.” 6. In Vidyacharan Shukla Vs. The Court must look squarely at the words of the statute and interpret them. It must interpret a taxing statute in the light of what is clearly expressed: It cannot imply anything which is not expressed; it cannot import provisions in the statutes so as to supply any assumed deficiency.” 6. In Vidyacharan Shukla Vs. Khubchand Baghel { AIR 1964 SC 1099 }, the Hon'ble Supreme Court held as follows :- “In the language of Section 34 of 1996 Act, the crucial words are “but not thereafter” used in the proviso to sub-section (3). This phrase would amount to an express exclusion within the meaning of Section 29 (2) of the Limitation Act, and would therefore bar the application of Section 5 of that Act. Parliament did not need to go further. To hold that the Court could entertain an application to set aside the award beyond the extended period under the proviso, would render the phrase “but not thereafter” wholly otiose. No principle of interpretation would justify such a result.” 7. In Hukumdev Narain Yadav vs. Lalit Narain Mishra { (1974) 2 SCC 133 }, the Hon’ble Apex Court held as follows :- “If on an examination of the relevant provisions it is clear that the provisions of the Limitation Act are necessarily excluded, then the benefits conferred therein cannot be called in aid to supplement the provisions of the Act.” 8. In Mangu Ram Vs. Muncipal Corporation of Delhi { (1976) 1 SCC 392 , at page 397}, the Hon'ble Supreme Court held as follows :- “It is not essential for the special or local law to, in terms, exclude the provisions of the Limitation Act. It is sufficient if on a consideration of the language of its provisions relating to limitation, the intention to exclude can be necessarily implied.” 9. In Union of India Vs. Popular Construction Co (2001) 8 SCC 470 , the Hon’ble Supreme Court held thus :- “There is no dispute that the Arbitration and Conciliation Act, 1996 is a Special Law and that Section 34 provides for a period of limitation different from that prescribed under the Limitation Act. The question then is whether exclusion in terms of Section 29 (2) of the Limitation Act, 1963 has been expressed in Section 34 of the above said Act. The question then is whether exclusion in terms of Section 29 (2) of the Limitation Act, 1963 has been expressed in Section 34 of the above said Act. Had the proviso to Section 34 merely provided for a period within which the Court could exercise its discretion, that would not have been sufficient to exclude Sections 4 to 24 of the Limitation Act because mere provision of a period of limitation in howsoever peremptory or imperative language is not sufficient to displace the applicability of Section 5. 10. From the averments filed in support of the Tax Case Revision it is made clear that the appeal has been filed well beyond the further period of 90 days over and above the initial 90 days period, as provided under Section 60 (1) of the Tamil Nadu Value Added Tax Act, 2006. 11. In the result, Tax Case Revision Petition SR.Nos.87191 of 2005 is dismissed in SR stage itself. No costs. Consequently, the connected Civil Miscellaneous Petition No. 1112 of 2005 is closed.