The Minister of Finance appealed an order granting the respondent an extension of time to file a notice of appeal regarding a tax assessment.
The respondent had filed his notice of appeal 37 days after the 90-day limitation period prescribed by the Retail Sales Tax Act.
The Divisional Court allowed the appeal, holding that the court has no jurisdiction to extend the express limitation period set out in the Act, and that the Minister was not estopped from relying on the limitation period.
