Pre-deposit default and unexplained delay barred merits hearing and defeated condonation of appeal delay

A prolonged and unexplained failure to comply with a pre-deposit condition barred the appeals from being heard on merits, and belated deposit without seeking extension did not cure the default. The appellate authority's dismissal and the Tribunal's affirmation were justified. The 367-day delay in filing was also not condoned because the explanation was limited to domestic reasons and ignorance of limitation, which did not amount to sufficient cause. No substantial question of law arose, so the orders below were left undisturbed and the Revenue obtained no relief.

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Issues: (i) Whether the appeals could be entertained on merits despite non-compliance with the pre-deposit condition directed by the appellate authority. (ii) Whether the delay of 367 days in filing the appeals deserved condonation under the Limitation Act, 1963.

Issue (i): The appellate authority had required the additional demand to be deposited in instalments as a condition for hearing the appeals. The amount was deposited only after a long and unexplained delay, and no extension of time had been sought. The earlier dismissal by the appellate authority and its affirmation by the Tribunal were therefore justified.

Conclusion: The appellant was not entitled to have the appeals heard on merits after such belated compliance with the pre-deposit condition.

Issue (ii): The explanation offered for the delay referred only to domestic reasons and ignorance of limitation. Such reasons did not amount to sufficient cause, particularly when the delay was substantial and remained unexplained.

Conclusion: The delay in filing the appeals was not liable to be condoned.

Final Conclusion: The court found no substantial question of law and declined to disturb the orders below, leaving the Revenue without relief.

Ratio Decidendi: A prolonged and unexplained failure to comply with a pre-deposit condition, coupled with an absence of sufficient cause for delay, does not justify appellate hearing on merits or condonation of delay.

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