Condonation of delay in tax appeals accepted where administrative red tape and public interest justified a merits-based approach.

A 722-day delay in filing tax appeals was condoned where the State explained that the lapse arose from administrative processing, file movement, internal approval, and time spent in the Government Pleader's office. The Court applied a justice-oriented approach, noting that condonation should not turn on technicalities when there is no deliberate inaction or lack of bona fides. It treated the substantial tax stake, public interest, and the preference for merits-based adjudication as relevant factors, and accepted that governmental decision-making may be slowed by procedural red tape within reasonable limits. Costs were imposed on the State.

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Issues: Whether the State had shown sufficient cause to condone 722 days' delay in filing tax appeals challenging the Tribunal's order.

Analysis: The delay was explained as arising from governmental administrative procedure, including movement of files, obtaining internal approval, and time consumed in the office of the Government Pleader. The Court noted that while the State is not entitled to special indulgence, applications for condonation must be considered with a justice-oriented approach where no deliberate inaction or lack of bona fides is shown. The substantial tax stake, the public interest involved, and the need to prefer adjudication on merits over technical dismissal were treated as relevant considerations. The Court also relied on the principle that governmental decision-making is often slow and encumbered by procedural red tape, and that such realities may constitute sufficient cause within reasonable limits.

Conclusion: The delay was condoned, the applications were allowed, and costs were imposed on the State.

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