Tribunal can't extend stay beyond 365 days yet HC can extend stay beyond that period by exercising w

Excise & Customs : After insertion of third proviso to section 35C(2A) by Finance Act, 2013, Tribunal may extend stay for period upto 365 days and not thereafter; however, High Court may, in exercise of its writ jurisdiction, pass a protective order provided delay in disposal of appeal is not attributable to conduct of assessee