Condonation of delay in tax appeals turns on sufficient cause, and illness-based explanation may justify a liberal approach.

Condonation of delay in filing tax appeals depends on whether the assessee shows sufficient cause, which is treated as an essentially factual inquiry. Here, the delay was substantial, but the assessee produced a medical certificate and explained that illness prevented timely filing. In the absence of contrary material or evidence of deliberate inaction, the Tribunal accepted the explanation and applied a liberal approach to avoid defeating substantial justice. The Tribunal's condonation of delay was therefore upheld, and no question of law arose for interference.

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Issues: Whether the Tribunal was justified in condoning the delay in filing the assessee's appeals against the assessment orders for the relevant assessment years.

Analysis: The delay was substantial, but the assessee supported the applications with a medical certificate and explained the inability to file the appeals within time on account of illness. The question of sufficient cause was treated as essentially factual. In the absence of material contradicting the medical certificate or showing deliberate inaction, the Tribunal accepted the explanation. The principles governing condonation of delay call for a liberal approach where substantial justice may otherwise be defeated.

Conclusion: The Tribunal was justified in condoning the delay, and no question of law arose for interference.

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