Condonation of delay requires sufficient cause; a later favourable legal development cannot justify years of inaction.

Condonation of an inordinate delay under section 5 of the Limitation Act, 1963 requires a fact-specific showing of sufficient cause. A liberal approach may apply to short delays, but prolonged inaction calls for strict scrutiny, and the applicant must show due care, caution, or circumstances beyond control. A later favourable development in law, by itself, does not justify filing an appeal after years of delay. On the stated facts, no sufficient cause was established, so the delay was not condoned and the belated appeal remained ineffective.

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Issues: Whether the delay of more than four years and seven months in filing the appeal before the first appellate authority deserved condonation on the ground of sufficient cause.

Analysis: The law of limitation is founded on public policy and the expression "sufficient cause" under section 5 of the Limitation Act, 1963 is to be applied on the facts of each case. A liberal approach may be adopted where the delay is short, but an inordinate delay requires strict scrutiny. The later pronouncement of law by the High Court could not, by itself, justify the belated filing of the appeal when the assessee had remained inactive for years after the assessment order. The delay was not shown to have occurred despite due care and caution or due to circumstances beyond control.

Conclusion: The delay was not condonable and the assessee was not entitled to relief on this ground.

Final Conclusion: The appeal failed for want of merit because no sufficient cause was established for the extraordinary delay, leaving the assessment and dismissal of the belated appeal undisturbed.

Ratio Decidendi: Condonation of delay under section 5 of the Limitation Act, 1963 depends on a fact-specific showing of sufficient cause, and an inordinate delay cannot be condoned merely because of a subsequent favourable legal development.

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