Can the Tax Appeals Tribunal Suo Moto raise the issue of the Objection Decision being statutorily barred.

“It is a well-established principle of law that courts and tribunals have an inherent duty to ascertain their jurisdiction and to ensure that proceedings before them are legally sound. Issues of competence of the proceedings and jurisdiction of the court can be raised at any time, and indeed, a court or tribunal may raise them suo moto if they become apparent from the record. The 60-day timeline in Section 51(11) TPA is a mandatory provision and self-executing whose non-compliance would render the objection decision invalid, directly affecting the Commissioner’s power to assess. The Tribunal had the undoubtable right and a duty to ensure that the decision challenged before it was legally compliant and not void.   The Court therefore finds that the Tribunal did not err in raising the matter suo moto.  This determination is however inconsequential because the court has determined that the consequent outcome of that inquiry was erroneous.”