Condonation of delay denied where internal file movement and administrative steps were not enough to justify late filing.

Internal movement of a file between offices and internal proposals to appeal did not, by itself, amount to sufficient cause for condoning a delay of about 64 days in filing the revenue appeal. The Tribunal noted that the appeal was authorised only after the limitation period had expired and was filed after further delay, which did not establish a bona fide justification. Condonation of delay was therefore refused.

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Issues: Whether the Revenue had shown sufficient cause for condonation of a delay of about 64 days in filing the appeal against the order of the Commissioner (Appeals).

Analysis: The delay was attributed to movement of the file between offices and internal proposals to file an appeal. The Tribunal held that such internal administrative movement, by itself, does not constitute sufficient cause or bona fide justification for condoning delay, particularly where the appeal was authorised after expiry of limitation and was filed only after further delay.

Conclusion: The application for condonation of delay was rejected.

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