Condonation of delay in revision proceedings turned on unexplained delay and absence of prior notice on limitation.

Delay in filing a revision application was not satisfactorily explained, so the Collector of Sales Tax was justified in rejecting it as time-barred. Payment required for admission of the revision did not amount to a decision on limitation, and no earlier stage had condoned the delay. The Court distinguished the cited precedent because the assessee there had been given notice on the condonation issue, whereas no such notice was issued in this matter. On those facts, no interference with the refusal to condone delay was warranted.

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Issues: Whether the Collector of Sales Tax was justified in refusing to condone the delay in filing the revision application and dismissing it as time-barred.

Analysis: The delay was found not to have been satisfactorily explained. No earlier stage had considered or allowed condonation of delay, and the requirement to pay a sum for admission of the revision did not amount to a decision on limitation. The Court distinguished the cited precedent on the basis that there the assessee had been put to notice on the question of condonation, whereas no such notice had been issued here.

Conclusion: The Collector was entitled to reject the revision application as time-barred, and no interference was called for.

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