Condonation of delay where assessee bona fide pursued tax adjustment request and had sufficient cause for late appeal filing.

Delay in filing an appeal before the Tribunal may be condoned where the assessee was bona fide pursuing a request for adjustment of balance tax liability and awaiting a reply, rather than acting without diligence. The omission to file within time was linked to that ongoing request and to the defect that the original assessment order had not been signed by the assessing authority. On those facts, the circumstances amounted to sufficient cause for condonation, and the appeal ought to be treated as filed in time.

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Issues: Whether the delay in filing the appeal before the Tribunal ought to have been condoned on the ground that the assessee was bona fide pursuing a request for adjustment and awaiting a reply.

Analysis: The assessee had sought adjustment of the balance tax liability and, while waiting for the final response, did not file the appeal within time. The delay was also associated with the defect that the original assessment order had not been signed by the assessing authority. The circumstances showed bona fide pursuit of another remedy and not want of diligence. Such facts constituted sufficient cause for condonation of delay.

Conclusion: The delay should have been condoned and the appeal treated as having been filed in time.

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