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Issues: Whether the delay in filing the second appeal was liable to be condoned on the facts shown by the assessee.
Analysis: The application for condonation was supported by an affidavit and a medical certificate explaining that the person conducting the case was ill and confined to bed. No counter-affidavit or rebuttal evidence was filed to dispute those facts. The rejection of the medical certificate rested mainly on the circumstance that some writing appeared in a different ink, which by itself was held insufficient to disbelieve the certificate or the affidavit. The expression "sufficient cause" was to receive a liberal construction so that substantial justice is advanced and a hearing on merits is not shut out on conjecture.
Conclusion: The delay ought to have been condoned and the appeal could not be dismissed as time-barred.