Condonation of inordinate delay requires proven sufficient cause; a fact-based refusal will stand absent perversity.

An inordinate delay in filing an appeal can be condoned only on proof of sufficient cause, and the burden lies on the appellant to establish the factual basis for the delay. The assessee failed to prove that a review application had been filed on 13.12.2000, remained inactive for years, and did not challenge the rejection communicated in 2007. The alleged admission in the State's earlier writ reply was not unequivocal, so the Tax Board's refusal to condone the eleven-year delay was supported by the record. The revisional court was not justified in interfering because the finding was factual and not shown to be perverse or legally erroneous.

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Issues: Whether the Tax Board was justified in refusing to condone the inordinate delay in filing the appeal against the SLSC order, and whether the revisional court could interfere with the Board's factual finding that no review application had been filed on 13.12.2000.

Analysis: The dispute centred on whether the assessee had established sufficient cause for condonation of an eleven-year delay in filing the appeal. The Court held that the burden lay on the assessee to prove that a review application under clause 5A of the 1989 Scheme had in fact been filed on 13.12.2000 and that the delay thereafter was justified. The assessee had no proof of such filing, had remained inactive for years, and had not challenged the rejection communicated on 08.02.2007. The alleged admission in the State's reply to earlier writ proceedings was found not to be unequivocal. Applying the principles governing limitation, the Court held that liberal construction of "sufficient cause" does not extend to cases involving false pleas, lack of diligence, and unexplained inordinate delay. The Board's finding was based on record and did not suffer from perversity.

Conclusion: The refusal to condone delay was upheld, and no ground was made out for revisional interference with the Tax Board's order.

Ratio Decidendi: Inordinate delay can be condoned only on proof of sufficient cause, and a revisional court will not interfere with a fact-based refusal to condone delay unless the finding is perverse or vitiated by a clear error of law.

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