Condonation of gross delay in tax appeal refused where no explanation covered the entire period of inaction.

Gross delay in filing a tax appeal cannot be condoned without a satisfactory explanation for the entire period of inaction, and the State is held to the same standard of diligence. The Court reiterated that limitation provisions serve finality and that a prior condonation order is of no assistance because delay must be assessed on its own facts. The suggested tax impact did not cure the complete absence of explanation for the 2432-day delay, so condonation was refused and the tax appeal and stay application were dismissed.

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Issues: Whether the State had shown sufficient cause to condone a delay of 2432 days in filing the tax appeal.

Analysis: The State offered no explanation for the substantial period between communication of the Tribunal's order and the later proposal to file the appeal. The Court held that limitation provisions are intended to confer finality and that a litigant, including the State, cannot claim condonation for gross delay without accounting for the entire period of inaction. The reliance on another condonation order was held to be of no assistance because delay is decided on its own facts, and the suggested tax impact did not justify overlooking the complete absence of explanation.

Conclusion: The delay was not condonable, and the application for condonation of delay was rejected, resulting in dismissal of the tax appeal and the stay application.

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