Sufficient cause for delay rejected where file movement showed lethargy, not bona fide explanation, in review filing.

A delay of more than 400 days in filing a review application was not condoned because the explanation showed only repeated movement of the file between departmental authorities, the CBDT, the Ministry of Law and standing counsel. The HC held that, although "sufficient cause" must be construed pragmatically, that standard cannot excuse casual and cavalier handling or apparent lethargy and inaction. On the facts, the explanation was neither bona fide nor satisfactory, so the condonation application was rejected.

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Issues: Whether the delay of more than 400 days in filing the review application was liable to be condoned on the ground of sufficient cause.

Analysis: The explanation for the delay showed prolonged movement of the file between departmental authorities, the Central Board of Direct Taxes, the Ministry of Law and successive standing counsel. The Court held that the explanation disclosed casual and cavalier handling of the matter rather than a bona fide and satisfactory cause. While the expression "sufficient cause" is to be construed pragmatically, that approach cannot be used to excuse apparent lethargy and inaction on the facts of the case.

Conclusion: The delay was not condoned and the application for condonation of delay was rejected.

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