Condonation of delay in tax revision requires bona fide, diligent explanation; negligence or unexplained delay will not suffice.

Delay in filing a tax revision petition under the Andhra Pradesh General Sales Tax Act is condonable only on proof of sufficient cause. The expression is construed liberally, but not to excuse negligence, inaction, lack of bona fides or unexplained delay. An explanation that is inconsistent with the prescribed departmental procedure and does not show reasonable diligence or prompt action will fail this test, especially where prejudice to the other side is shown. On the facts stated, the delay was not supported by sufficient cause and was not liable to be condoned.

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Issues: Whether the delay in filing the tax revision case could be condoned on the basis of sufficient cause.

Analysis: The proviso to sub-section (1) of section 22 of the Andhra Pradesh General Sales Tax Act, 1957 permits admission of a revision petition filed beyond ninety days only if sufficient cause is shown. The expression "sufficient cause" is to be construed liberally, but not so as to excuse negligence, inaction, lack of bona fides, or unexplained delay. The explanation offered for the delay was found to be inconsistent with the prescribed departmental procedure and did not show reasonable diligence or prompt action. The delay was also considered prejudicial to the other side in the circumstances of the case.

Conclusion: The delay was not supported by sufficient cause and was not liable to be condoned.

Ratio Decidendi: Condonation of delay requires a bona fide, reasonable and adequately explained cause showing due diligence and proper conduct; negligence, inaction, or an explanation contrary to the governing procedure will not constitute sufficient cause.

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