Condonation of minor procedural delay can preserve credit where the statute allows it and no reasons justify refusal.

A trivial one-day delay in filing a declaration under Rule 57T should not, by itself, defeat credit where the statutory scheme permits condonation of delay up to three months. Refusal to condone required adequate reasons, and none were given by the lower authorities. Credit was therefore not justified in being denied solely on the ground of the minimal procedural delay, and the assessee obtained consequential relief.

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Issues: Whether a delay of one day in filing the declaration under Rule 57T could be condoned and the credit denied on that ground.

Analysis: The delay was only one day, and the statutory scheme permitted condonation of delay up to three months. The lower authorities gave no adequate reasons for refusing to condone the delay. Denial of credit merely because of a one-day delay was not justified in the circumstances.

Conclusion: The delay of one day in filing the declaration was condoned, and the appeal was allowed with consequential benefit in favour of the assessee.

Final Conclusion: The denial of credit based solely on a minimal procedural delay was set aside, and the assessee obtained the consequential relief sought.

Ratio Decidendi: Where the statute permits condonation of delay, a trivial delay should not be used to deny substantive credit absent reasons justifying refusal to condone.

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