Delay condonation in statutory tax appeals may follow credible medical evidence and should not be rejected mechanically.

Under the Puducherry Value Added Tax Act, 2007, a statutory appeal filed after the initial 30-day period may still be admitted within a further 30 days if sufficient cause is shown. The text explains that medical evidence and supporting documents were accepted as credible material showing the delay was not wilful or wanton. On that basis, a refusal to entertain the appeal for want of jurisdiction was treated as unsustainable, and the delay was liable to be condoned so the appeal could be heard on merits.

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Issues: Whether the delay in filing the statutory appeal under the Puducherry Value Added Tax Act, 2007 ought to have been condoned on showing sufficient cause, and whether the appellate authority was justified in refusing to entertain the appeal for want of jurisdiction beyond the prescribed period.

Analysis: The appeal was filed beyond the initial 30-day period, but the statutory scheme under section 47 permits admission within a further 30 days if sufficient cause is shown. The petitioner supported the delay with medical evidence and documents, and the delay was treated as neither wilful nor wanton. In these circumstances, the refusal to consider the appeal on the ground of lack of jurisdiction was found unsustainable, and the delay was held liable to be condoned so that the appeal could be examined on merits.

Conclusion: The delay should have been condoned and the appeal entertained for decision on merits; the refusal to admit the appeal was set aside in favour of the petitioner.

Ratio Decidendi: Where the statute permits a limited extension of time on sufficient cause being shown, a delay supported by credible medical evidence cannot be rejected mechanically on a supposed want of jurisdiction, and the appeal should be considered on merits.

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