Condonation of delay in sales tax appeals fails where the only explanation is a later Supreme Court ruling.

A delayed appeal under section 31(1) of the Tamil Nadu General Sales Tax Act, 1959 must be filed within thirty days of service of the assessment order unless sufficient cause is shown for the delay. A later Supreme Court judgment cannot by itself explain or excuse a failure to appeal within the statutory period, because it is not a cause existing during limitation. The revision petitions therefore failed, and the refusal to entertain the belated appeals was upheld, leaving the assessment orders undisturbed.

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Issues: Whether delay in filing the appeals against the assessment orders could be excused on the ground that the appellants came to know of the alleged non-liability to sales tax only after a later Supreme Court decision.

Analysis: Under section 31(1) of the Tamil Nadu General Sales Tax Act, 1959, an appeal must be filed within thirty days from service of the assessment order, though the appellate authority may admit a delayed appeal on sufficient cause being shown. The delay in the present case was not attributable to any cause existing within the limitation period. The appeals were filed only after a subsequent judgment of the Supreme Court, and a later judicial pronouncement cannot be treated as sufficient cause for not filing an appeal within the statutory time.

Conclusion: The delay was not liable to be condoned, and the refusal to entertain the belated appeals was justified.

Final Conclusion: The revision petitions failed and the assessment orders stood undisturbed.

Ratio Decidendi: A subsequent judgment of a court, rendered after expiry of the limitation period, does not constitute sufficient cause for condonation of delay in filing an appeal.

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