Condonation of delay in tax appeals requires a credible explanation; a bald mistake-of-law plea will not suffice.

A belated tax appeal can be condoned only on a credible, specific and satisfactory explanation showing sufficient cause. A bare plea of mistake of law, unsupported by particulars and inconsistent with the assessee's conduct, will not justify inordinate delay, especially where similar litigation was already known to exist. Once delay is not properly explained, the appellate order granting relief on merits cannot stand, and revisional interference may be justified if the delay was wrongly condoned by a cryptic order. The text records a mixed result across assessment years, with some belated appeals rejected and related revisional orders unsustainable in others.

---

---

Issues: (i) Whether the long and inordinate delay in filing the appeals was supported by sufficient cause and could be condoned. (ii) Whether the appellate order granting relief on merits could survive when the appeal itself was filed belatedly without sufficient explanation for the delay.

Issue (i): Whether the long and inordinate delay in filing the appeals was supported by sufficient cause and could be condoned.

Analysis: The explanation for delay was that the assessee waited for the outcome of litigation concerning the levy on wires drawn from tax-paid wire rods. The Court found that no convincing basis was shown for the failure to challenge the assessments earlier, that the affidavit before the appellate authority was bald, and that the conduct of the assessee did not support the plea of mistake of law or sufficient cause. The existence of similar litigation by other assessees, including related businesses, showed that the assessee could not plausibly claim ignorance or a bona fide mistaken impression. The delay was thus not satisfactorily explained, and the appellate authority ought to have rejected the appeals in limine.

Conclusion: The delay was not liable to be condoned and the assessee failed to establish sufficient cause.

Issue (ii): Whether the appellate order granting relief on merits could survive when the appeal itself was filed belatedly without sufficient explanation for the delay.

Analysis: Once the delay was found to be unjustified, the consequential order on merits could not be sustained. The Commissioner's revisional interference was held to be justified because the appellate authority had improperly condoned the delay by a cryptic order and proceeded to grant relief. In the connected appeals where the delay issue led to rejection, the dismissal followed; in the remaining appeals, the revisional orders were unsustainable for the relevant assessment years and relief had to be granted.

Conclusion: The consequential appellate relief was invalid in the dismissed appeals, but the revisional orders were unsustainable in the allowed appeals.

Final Conclusion: The decision upheld rejection of the belated appeals for some assessment years while granting relief in the remaining appeals, resulting in a mixed outcome on the delay and revision questions.

Ratio Decidendi: A belated tax appeal can be entertained only when the appellant demonstrates sufficient cause by a credible and specific explanation; a bald plea of mistake of law or unexplained inaction does not justify condonation of inordinate delay.

---