With no explanation, chose the best option from "A", "B", "C" or "D". petition for review of any decision or determination relating to the liability of any person for any unpaid money or claim collectible by the Department of Revenue, for or on behalf of the City or the School District of Philadelphia, including, but not limited to, any tax, water or sewer rent, license fee or other charge, and interest and penalties thereon, shall be filed with the Tax Review Board within 60 days after the mailing of a notice of such decision or determination to the petitioner. (Emphasis added). The failure to timely appeal an administrative agency action is a jurisdictional defect. Falcon Oil Co., Inc. v. Department of Envtl. Res., 148 Pa.Cmwlth. 90, 609 A.2d 876 (1992). See also Robinson v. Pennsylvania Board of Probation and Parole, 525 Pa. 505, 582 A.2d 857 (1990) (<HOLDING>). The word “shall” by definition is mandatory,

A: holding tardy filings go to the jurisdiction of the tribunal to entertain a cause
B: holding prohibition lies to prevent a lower tribunal from acting in excess of its jurisdiction but not to prevent an erroneous exercise of jurisdiction
C: holding district court of appeal has jurisdiction to entertain states appeal from a nonfinal order of the county court certified to be of great public importance
D: holding district court lacked jurisdiction to entertain a challenge to a removal order because such challenges must be raised in a petition for review
A.