Timelines Are Not a technicality That can be cured Under Article 159 of the Constitution

An appeal filed out of time is not curable under Article 159 and therefore this court cannot state that the Tribunal could still hear and determine the appeal under the auspices of Article 159 of the Constitution. Filing an appeal out of time and without the leave of the Tribunal as stipulated by section 13(3) of the Tax Appeals Tribunal Act was fatal and divested the Tribunal of jurisdiction to hear and determine the appeal.