Summarize the following court judgment. Appeals Nos. 1458 1459 of 1970. Appeal by special leave from the judgment and order dated the 1st January	 1970 of the Allahabad High Court in S.T.R. No. 344 and S.T.R. No. 347 of 1967. 745 N. D. Karkhanis and 0. P. Rana	 for the appellant. No. appearance	 for the respondent. The Judgment of the Court was delivered by SARKARIA	 J. The common question of law for determination in these appeals by special leave is ': Whether section 14(2) of the Limitation Act	 in terms	 or	 in principle	 can be invoked for excluding the time spent in prosecuting an application under Rule 68(6) of the J.P. Sales Tax Rules for setting aside the order of dismissal of appeal in default	 under the U.P. Sales Tax Act	 1948 (for short	 the Sales= Act)	 from computation of the period of limitation for filing a revision under that Act? It arises out of these circumstances. The respondent	 M/s. Parson Tools and Plants (hereinafter referred to as the assesse) carries on business at Kanpur. The Sales tax Officer assessed tax for the assessment years	 1958 1959 and 1959 60	 on the	 assessee by two separate orders. The assessee filed appeals against those orders before the Appellate Authority. On May 10	 1963	 when the appeals came up for hearing	 the assessee was absent. The appeals were	 therefore	 dismissed in default by virtue of Rule 68(5) of the U.P. Sales tax Rules. Sub rule (6) of Rules 68 provided for setting aside such dismissal and re admission of the appeal. On the same day (May 10	 1963)	 the assessee made two applications in accordance with Sub rule (6) for setting aside the dismissal. During the pendency of those applications	 Sub rule (5) of Rule 68 was declared ultra vires the rule making authority by Manchanda J. of the High Court who further held that the Appellate Authority could not dismiss an appeal in default but was bound to decide it on merits even though the appellant be absent. When these	 applications under Rule 68(6) came up for hearing	 on 20 10 1964	 the Appellate Authority dismissed them outright in view of the ruling of Manchanda J. Against the order of dismissal of his appeals	 the assessee on 16 12 1964 filed two revision petitions under section 10 of the Sales tax Act		 before the Revisional Authority (Judge (Revisions) Sales tax). These revision petitions having been filed more than 18 months after the dismissal of the appeals	 which was the maximum	 period of limitation prescribed by sub . 73) of s 10 were prima facie time barred. They were however	 accompanied by two applications in which the assessee prayed for exclusion of the time spent by him in prosecuting the abortive proceedings under Rule 68(6) for setting aside the dismissal of his appeals. The Revisional Authority found that the assessee had been pursuing his remedy under Rule 68(6) with due diligence and in good faith. It therefore excluded the time spent in those proceedings from computation of limitation by applying section 14	 Limitation Act and in consequence	 held that the revision petitions were within time. On the motion of the Commissioner of Sales tax	 the Revisional Authority made two references under section 11 (I) of the Sales tax Act to the High Court for answering the following question of law : "Whether under the circumstances of the case	 section 14 of the Limitation Act extended the period for filing 746 of the revisions by the time during which the restoration applications remained pending as being prosecuted bona fide. " The references were heard by a Full Bench of three learned Judges	 each of whom wrote a separate Judgment. Dwivedi J. with whom Singh J. agreed after reframing the question held "that the time spent in prosecuting the application for setting aside the order of dismissal of appeals in default can be excluded from computing the period of limitation for filing the revision by the application of the principle underlying section 14(2). Limitation Act. " Hari Swarup J. was of the opinion: "The Judge (Revisions) Sales tax while hearing the revisions under section 10 of the U.P. Sales Tax Act does not act as a Court but only as a revenue tribunal and hence the provisions of the Indian Limitation Act cannot apply to proceedings before him. If the Limitation Act does not apply then neither section 29(2) nor section 14(2) of the Limitation Act will apply to proceedings before him. 	 The learned Judge was further of the view that the principle of section 14(2) also, could not be invoked to extend the time beyond the maximum fixed by the Legislature in sub section (3 B) of section 10 of the Sales tax Act. Sub section (2) of section 14, Limitation Act, runs thus In computing the period of limitation for any application	 the time during which the applicant has been prosecuting with due diligence another civil proceedings	 whether in a Court of first instance or of. appeal or revision	 against the same party for the same relief shall be excluded	 where such proceeding is prosecuted in good faith in a Court which	 from defect of jurisdiction or other cause of a like nature	 is unable to entertain it." (emphasis added). If will be seen that this sub section will apply only if (1) both the prior and subsequent proceedings are civil proceedings prosecuted by the same party; (2) the proceedings had been prosecuted with due diligence and in good faith; (3) the failure of the prior proceedings was due to a defect of jurisdiction or other cause of a like nature; (4) both the proceedings are proceedings in a Court. Mr. Karkhanis	 learned Counsel appearing for the appellant does not dispute the view taken by the High Court that the Proceedings in question under the Sales tax Act could be deemed as civil proceeding. Learned Counsel	 however	 contends that the authorities	 irrespective of whether they exercise	 original	 appellate or revisional 747 jurisdiction under the Sales tax Act are not 'Courts ' within the ' contemplation of section 14(2) of the Limitation Act. It is pointed out that his question stands concluded by this Court 's decision in Jagannath Prasad vs State of U.P.(1) Mr. Karkhanis is right that this matter is no longer res Integra. In Shrimti Ujjam Bhai vs State of U.P.(2) Hidayatullah J. (as he hen was) speaking for the Court	 observed : "The taxing authorities are instrumentalities of the State	. They are not a part of the legislature	 nor are they a part of the judiciary. Their functions are the assessment and collection of taxes and in the process of assessing taxes	 they follow a pattern of action which is considered Judicial. They are not thereby converted into Courts of Civil judicature. They will remain the instrumentalities of the State and are within the definition of "State" in Article 12. " The above observations were quoted with approval by this Court Jagannath Prasad 's case (supra)	 and it was held that a Sales tax officer under U.P. Sales tax Act	 1948 was not a Court within the meaning of section 195 of the Code of Criminal Procedure although he is required to perform certain quasi judicial functions. The decision in jaganath Prasad 's it seems	 *as not brought to the notice of he High Court. In view of these pronocements of this Court	 here is no room for argument that the Appellent Authority and the judge (Revisions) Sales tax exercising jurisdiction under the Salestax Act	 are courts. " They are merely administrative Tribunals and not courts." Section 14	 Limitation Act	 therefore does not	 in terms apply to proceedings before such Tribunals. Further question that remains is : Is the general principle underlying section 14 (2) applicable on grounds of Justice	 equity and good conscience for excluding the time spent in prosecuting the abortive applications under Rule 68 (6) before the Appellate Authority.	 for computing limitation for the purpose of revision applications. Mr. Karkhanis maintains that the answer to this question	 also	 must be in the negative because definite indications are available in the scheme and language of the Sales tax Act	 which exclude the application of section 14(2)	 Limitation Act even in principle or by or by analogy. Learned Counsel further submits that the ratio of the Privy Council decision in Ramdute Ramkissen Dass vs E. D. Sesson & Co.(s) relied upon by the majority judgment of the High is not applicable for computing limitation prescribed under the Sales tax Act. Reference in this connection has been made to Purshottam Dass Hassaram vs Impex (India) Lid.(4) wherein a Division Bench of the Bombay High Court explained the rule of decision in Ramdutt 's case (supra) and found it to be inapplicable for the purpose of computing limitation for ap plications under the . (1) ; (2) [1963] 1	 S.C.R. 778. (3) AlR 	 (4) A.I.R. 1954 Bom	 309 748 The material pail of s.10 runs thus : "(3) (i). The Revision Authority. . may	 for the purpose of satisfying itself as to the legality or propriety of any order made by any appellate or assessing authority under this Act	 in its discretion call for and examine	 either on its own motion or on the application of the Commissioner of gales tax or the person aggrieved	 the record of such order and pass such order as it may think fit. * * * * * * (3A). . (3B) The application under sub section (3) shall be made within one year from the date of service of the order complained of	 but the Revising Authority may on proof of sufficient cause entertain an application within a further period of six months. " Three features of the scheme of the above provision are noteworthy. The first is that no limitation has been prescribed for the suo motu exercise of its jurisdiction by the Revising Authority. The second is that the period of one year prescribed as	 limitation for filing an application for revision by the aggrieved party is unusually long. The third is that the Revising Authority has no discretion to extend this period beyond a further period of six months	 even on sufficient cause shown. As rightly pointed out in the minority judgment of the High Court	 pendency of proceedings of the nature contemplated by section 14(2) of the Limitation Act	 may amount to a sufficient cause for condoning the delay and extending the limitation for filing a revision application	 but section 10 (3 B) of the Sales tax Act	 gives no jurisdiction to the Revising Authority to extend the limitation	 even in such a case	 for a further period of more than six months. The three star features of the scheme and language of the above provision	 unmistakably show that the legislature has deliberately excluded the application of the principles underlying sections 5 and. 14 of the Limitation Act	 except to the extent and in the truncated form embodied in sub section (3 13) of section 10 of the Sales tax Act. Delay in disposal of revenue matters adversely affects the steady inflow of reve nues and the financial stability of the State. Section 10 is therefore designed to	 ensure speedy and final determination of fiscal matters within a reasonably certain time schedule. It cannot be said that by excluding the unrestricted application of the principles of sections 5 and 14 of the Limitation Act	 the Legislature has made. the provisions of section 10	 unduly oppressive. In most cases	 the discretion to extend limitation	 on sufficient cause being shown for a further period of six months only	 given by sub section ( 3_B) would be enough to afford relief. Cases are no doubt conceivable where an aggrieved party	 despite sufficient cause	 is unable to make an 749 application for revision within this maximum period of 18 months. Such harsh cases would be rare. Even	 in such exceptional cases of extreme hardship	 the Revising Authoritly may	 on its own motion	 entertain revision and grant relief. Be that as it may	 from the scheme and language of section 1 0	 the intention of the Legislature to exclude the unrestricted application of the principles of sections 5 and 10 of the Limitation Act is manifestly clear. These provisions of the Limitation Act which the Legislature did not	 after due application of mind	 incorporate in the Sales tax Act	 cannot be imported into it by analogy. An enactment being the will of the legislature	 the paramount rule of interpretation	 which overrides all others	 is that a statute is to be expounded "according to the intent of them that made it". "The will of 'the legislature is the supreme law of the land	 and demands perfect obdience".(1) "Judicial power is never exercised" said Marshall C. J. of the United States	 "for the purpose of giving effect to the will of the Judges; always for the purpose of giving effect to the will of the Legislature; or in other words	 to the will of the law". If the legislature wilfully omits to incorporate something of an 'analogous law in a subsequent statute	 or even if there is a casus omissus in a statute	 the language of which is otherwise plain and unambiguous	 the Court is not competent to supply the omission by engrafting on it or introducing in it	 under the guise of interpretation	 by analogy or implication	 something what it thinks to be a general principle of justice and equity. To do so would be entrenching upon the preserves of Legislatures	 'The primary function of a court of law being jus dicere and not jus dare. ' In the light of what has been said above	 we are of the opinion that the High Court was in error in importing whole hog the principle of section 14(2) of the Limitation Act into section 10 (3 B) of the Sales tax Act. The ratio of the Privy Council decision in Ramdutt Ramkissen Dass vs E. D. Sasson & Co. (Supra) relied upon by the High Court is not on speaking terms with the clear language of section 10 (3 B) of the Sales tax Act. That decision was rendered long before the passage of the Indian . It lost its efficacy after the enactment of the which contained a specific provision in regard to exclusion of time from computation of limitation. The case in point is Purshottam Dass Hussaram vs Index (India) Ltd. (supra). In this Bombay case	 the question was	 whether the suit was barred by limitation. It was not disputed that Article 115 of the Limitation Act governed the limitation and if no other factor was to be taken into consideration	 the suit was filed beyond time. But what was relied upon by the plaintiff for the purpose of saving (i) see Maxwell on interpretation of statutes	 11th Edn.	pp.l	 2 and 25l	 750 limitation was the fact that there were certain infructuous arbitration		 Proceedings and if the time taken in prosecuting those proceedings was eXcluded under section 14	 the suit would be within limitation. It was held that if section 14 were to be construed strictly	 the plaintiff would not be entitled to exclude the period in question. On the authority of Ramdutt Ramkissen 's case (supra)	 it was then contended that. the time taken in arbitration proceedings should be excluded on the analogy of section 14. This contention was also negatived on the ground that since the decision of the Privy Council	 the legislature had in section 37(5) of the 	 provided as to what extent the provisions of the Limitation Act would be applicable to the proceedings before the arbitrator. Section 37(5) was as follows : "Where the cow orders that an award be set aside or orders	 after the commencement of an arbitration	 that the arbitration agreement shall cease to have effect with respect to the difference referred	 the period between the commencement of the arbitration and the date of the order of the Court shall be excluded in computing the time prescribed by the Indian Limitation Act	 1908	 for the commencement of the proceedings (including arbitration) with respect to the difference referred. " The reasons advanced	 the observations made and the rule enunciated by Chagla C.J.	 who spoke for the Bench in that case	 are opposite and may be extracted with advantage ". . we have now a statutory provision for exclusion of time taken up in arbitration Pr when a suit Is filed	 and the question arises of computing the period of limitation with regard to that suit	 and the time that has got to be excluded is only that time which is taken up as provided in section 37(5). There must be an order of the Court setting aside an award or there must be an order of the Court declaring that the arbitration agreement shall cease to have effect	 and the period between the commencement of the arbitration and the date of this order is the period that has got to be excluded. it is therefore no longer open to the Court to rely on section 14 Limitation Act as applying by analogy to arbitration proceedings. If the Legislature intended that section 14 should apply and. that all the time taken up in arbitration proceedings should be excluded	 then there was no reason to enact section 37(5). 	 The very fact that section 37(5) has been enacted clearly shows that the whole period referred to in. a	 49 Limitation Act is not to be excluded but the limited '. indicated in section 37(5). * * * * * * 751 "it may seem rather curious and it may also in certain cases result in hardship as to why the legislature should not have excluded all time taken up in good faith before an arbitrator just as the time taken up in prosecuting a suit or an appeal in good faith is excluded. But obviously the Legislature did no t intend that parties should waste time infructuous proceedings before arbitrators. The Iegisla ture has clearly indicated that limitation having once begun to run	 no time could be excluded merely because parties chose to go before an arbitrator without getting an award or without coming to Court to get the necessary order indicated in section 37(5). " What the learned Chief Justice said about the inapplicability of section 14	 Limitation Act	 in the context of section 37(5) of the 	 holds good with added force with reference to section 10 (3 B) of the Sales tax Act. Thus the principle that emerges is that if the legislature in a special statute prescribes a certain period of limitation for filing a particular application thereunder and provides in clear terms that such period on sufficient cause being shown	 may be extended	 in the maximum	 only upto a specified time limit and no further	 than the tribunal concerned has no jurisdiction to treat within limitation	 an application filed before it beyond such maximum time limk specified in the statute	 by excluding the time spent in prosecuting in good faith and due diligence any prior proceeding on the analogy of section 14(2) of the Limitation Act. We have said enough and we may say it again that where the legislature clearly declares its intent in the scheme and language of a statute	 it is the duty of the court to give full effect to the same without scanning its wisdom or policy	 and without engrafting	 adding or implying anything which is not congenial to or consistent with such expressed intent of the law giver; more so if the statute is a taxing statute. We will close the discussion by recalling what Lord Hailsham (1) has said recently	 in regard to importation of the principles of natural justice into a statute which is a clear and complete Code	 by itself : "It is true of course that the courts will lean heavily 	against any construction of a statute which would be manifestly fair. But they have no power to amend or supplement the language of a statute merely because in one view (1)At P. 11 in Pearl Berg vs Varty 	 752 of the matter a subject feels himself entitled to a larger degree of say in the making of a decision than a statute accords him. Still less is it the functioning of the courts to form first a judgment on the fairness of an Act of Parliament and theft to amend or supplement it with new provisions so as to make it conform to that judgment. " For all the reasons aforesaid	 we are of the opinion that the object	 the scheme and language of s.10 of the Sales tax Act do not permit the invocation of s.14(2) of the Limitation Act	 either	 in terms	 or	 in principle	 for excluding the time spent in prosecuting proceedings for setting aside the dismissal of appeals in default	 from com putation of the period of limitation prescribed for filing a revision under the Sales tax. Accordingly	 we answer the question referred	 in the negative. In the result	 we set aside the judgment of the High Court and accept these appeals. Since the appeals have been heard ex parte	 there will be no order as to costs.

The Sales Tax Officer assessed tax for the assessment years 1958 1959 and 1959 60	 on the respondent assessee by two separate orders. The assessee filed appeals against those orders before the Appellate Authority. On May 10	 1963	 when the appeals came up for hearing	 the assessee was absent. The appeals were	 therefore. dismissed in default by virtue of Rule 68(5) of the U.P. Sates tax Rules. Sub rule (6) of Rule 68. provided for setting aside such dismissal and for re admission of the appeal. On the same day (May 10	 1963)	 the assessee made two applications in accordance with Sub rule (6) for setting aside the dismissal. During the pendency of those applications	 Subrule (5) of Rule 68 was declared ultra vires the rule making authority by Manchanda J. of the High Court who further held that the Appellate Authority could not dismiss an appeal in default but was bound to decide it on merits even though the appellant be absent. When these applications under r. 68(6) came up for hearing. on 20 10 64	 the Appellate Authority dismissed them outright in view of the ruling of Manchanda J. Against the order of dismissal of his appeals	 the assesees on 16 12 1964 filed two revision petitions under section 10 of the Sales tax Act	 before the [Judge (Revisions) Sales tax]. These revisions petitions having been filed more than 18 months after the dismissed of the appeals which was the maximum period of limitation prescribed by sub section (3) of section 10 were prima facie time barred. They were however	 accompanied by two application 's in which the assessee prayed for exclusion of the time spent by him in prosecuting the abortive proceedings under r. 68(6) for setting aside the dismissal of his appeals. The Revisional Authority found that the assessee had been pursuing his remedy under r. 68(6) with due diligence and in good faith. It therefore excluded the time spent in those proceedings from computation of limitation by applying section 14	 Limitation Act and in consequence	 held that the revision petitions were within time. On the motion of the Commissioner of Sales tax. the Judge (Revisions) Sales *ax made two references under section 11(1) of the Sales_tax Act to the High Court for answering the following question of law "Whether under the Circumstances of the case	 section 14 of the Limitation Act extended 'the period for filing of the revisions by the time during which the restoration applications remained pending as being prosecuted bona fid. " The references were heard by a Full Bench of three learned Judges each of whom wrote a separate Judgment. Dwivedi J. with whom Singh J. agree utter refraining the question held "that the time spent in prosecuting the application for setting aside the order of dismissal of appeals in default can be 744 excluded from computing the period of limitation for filing the revision by the application of the principle underlying section 14(2)	 Limitation Act. " Hari Swarup J. was of the opinion : "The Judge (Revisions) Sales tax while hearing the revisions under section 10 of the U.P. Sales Tax Act does not act as a Court but only as a revenue tribunal and hence the provisions of the Indian Limitation Act cannot apply to proceedings before him. If the Limitation Act does not apply then neither section 29(2) nor is 14(2) of the Limitation Act will apply to proceedings before him." The learned Judge was further of the view that the principle of section 14(2) also	 could not be invoked to extend the time beyond the maximum fixed by the Legislature in sub section (3 B) of section 10 of the Sales tax Act. These appeals have been preferred on the basis of the special leave granted by this court. Allowing the appeals	 HELD : (i) If the legislature wilfully omits to incorporate something of an analogous law in a subsequent statute	 or even if there is a casus omissus in a statute	 the language of which is otherwise plain and unambiguous	 the Court is not competent to supply the omission by engrafting on it or introducing in it	 under the guise of interpretation	 by analogy or implication	 something what it thinks to be. a general principle of justice and equity. To do so "would be entrenching upon the preserves of Legislature"	 the primary function of a court of law being jus dicere and not jus dare. [749D E] (ii) If the ' legislature in a special statute prescribes a certain period of limitation for filing a particular application thereunder and provides in 'clear terms that such period on sufficient cause being shown	 may be extended	 in the maximum	 only upto a specified time limit and no further	 then the tribunal concerned has no jurisdiction to treat within limitation	 an application filed before it beyond such maximum time limit specified in the statute	 by excluding the time spent in prosecuting in good faith and due diligence any prior proceeding on the analogy of section 14(2) of the Limitation Act. [751D E] Ramdutt Ramkissen Dass vs E. D. Sesson & Co. A.I.R. 1929	 P.C. 103 and Purshottam Dass Hassaram vs Impex (India) Ltd. A.I.R. 1954 Bom. 309	 referred to. (iii) In view of the pronouncements of this Court in Shrimati Ujjani Bhai vs State of U.P.	 and jagannath Prasad vs State of U.P. ; 	 there is no room for argument that the Appellate Authority and the Judge (Revisions) exencising jurisdiction under the U.P. Sales Tax Act	 1948	 are 'Courts '. They are merely administrative Tribunals and "not courts". Section 14	 Limitation Act	 therefore	 does not	 in terms apply to proceedings before such Tribunals. [747E] (iv) Three features of the scheme of provisions of section 10(3)(i) and section 10(3B) are noteworthy. The first is that no limitation has been prescribed for the suo matu exercise of its jurisdiction by the Revising Authority. The second is that the period of one year prescribed as limitation for filing an application for revision by the aggrieved party is unusually long. The third is that the Revising Authority has no discretion to extend this period beyond a further period of six months	 even on sufficient cause shown. The three stark features of the scheme and language of these provisions	 unmistakably show that the legislature has deliberately excluded the application of the principles of Ss. 5 and 14 of the Limitation Act. except to the extent and in the truncated form embodied in sub section (3 B) of section 10 of the Act. [748D F]