Condonation of delay denied where retrospective amendment did not excuse prolonged inaction in filing income-tax appeals.

Inordinate delay in filing appeals under section 253(3) was not condoned because the assessee failed to show sufficient cause. The Tribunal held that a retrospective amendment to section 43B did not explain prolonged inaction, particularly where the amendment had been in force long before the appeals were filed. It reiterated that limitation may be applied liberally only when no negligence, inaction, or lack of bona fides is shown, and that sympathetic considerations cannot justify condonation of extreme delay. On these facts, the delay of 1266 to 3602 days remained unexplained and the condonation request was rejected.

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Issues: Whether the assessee had shown sufficient cause for condonation of the inordinate delay in filing the appeals under section 253(3) of the Income-tax Act, 1961.

Analysis: The appeals were filed with delays of 1266 to 3602 days. The explanation that the delay arose because of the retrospective amendment relating to section 43B did not justify the prolonged inaction, especially when the amendment had come into force long before the appeals were filed. The Tribunal applied the settled principle that limitation provisions are to be construed liberally only where no negligence, inaction, or want of bona fides is shown, and that inordinate delay cannot be condoned merely on sympathetic considerations.

Conclusion: The assessee failed to establish sufficient cause for the delay, and the request for condonation was rejected.

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