5 . I have gone through the appeal paper books and both Order-in-Original and Order-in-Appeal passed by the Refund Sanctioning Authority as well as Commissioner (Appeals) respectively. The ground taken by the appellant here is not available as its submission before them except a noting that few days (4 days) delay has occurred due to Covid-19 Pandemic. However, Hon’ble Supreme Court’s order being law of land and the authorities below can not take a plea that they are unaware of the law declared by the Hon’ble Supreme Court specifically under Article 142 of Constitution of India in exercise of power to ensure complete justice with a direction to communicate it to all concerned authorities that the order is having binding effect within the meaning of Article 141 of the Constitution of India, on all courts, Tribunals and Authorities. In the said suo-muto writ petition (Civil) 3/2020, it has been clearly held that period of limitation in all such proceedings, irrespective of the limitation prescribed under the General Law or Special Laws, whether condonable or not, shall stand extended w.e.f. 15.03.2020 till further orders and on March 8, 2021, the order passed by it would be covering the Appellant’s case, the relevant portion of which would read;
