Condonation of delay requires sufficient cause; substantial revenue alone cannot justify overlooking an unexplained delay.

Delay can be condoned only on a clear and satisfactory showing of sufficient cause, and the reasons recorded must disclose that basis. The Court noted that the Tribunal relied on the quantum of revenue involved and also touched the merits while dealing with condonation, but substantial revenue by itself does not justify condonation. As the impugned order did not record a valid explanation for the delay, the condonation was held unsustainable. The appeals were allowed and the matter was remanded to the Tribunal for decision on the questions of law in accordance with law.

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Issues: Whether the Tribunal was justified in condoning the Revenue's delay in filing the appeals and in setting aside the first appellate order without a valid explanation for the delay.

Analysis: The appeal turned on the settled principle that delay can be condoned only on a satisfactory showing of sufficient cause. The Court noted that the Tribunal had relied on the quantum of revenue involved and had also adverted to the merits while deciding the condonation application. Following the earlier Division Bench view, the Court held that mere involvement of substantial revenue does not by itself justify condonation, and that the existence of sufficient cause must be discernible from the reasons recorded in the order. Since the impugned order did not furnish a valid basis for condoning the delay, the Tribunal's order could not be sustained.

Conclusion: The condonation of delay was held unsustainable and the appeals were allowed, with the matter sent back to the Tribunal for decision on the questions of law in accordance with law.

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