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Issues: Whether the delay in filing the revenue's appeal should be condoned and the appeal admitted.
Analysis: The delay was held to have been explained only in a mechanical manner, with no plausible or acceptable justification for the time taken at successive administrative stages. The explanation based on governmental file movement and bureaucratic process was not accepted as sufficient cause. Reliance was placed on the principle that the Government does not enjoy a separate period of limitation and must show reasonable and bona fide grounds for delay.
Conclusion: The delay was not condoned and the appeal was declined admission.