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Issues: Whether the revenue had shown sufficient cause to condone the delay of 331 days in filing the appeal and whether the delay should be excused despite the prejudice caused to the assessee.
Analysis: The delay was considered in the light of the explanation furnished by the revenue and the prejudice occasioned to the assessee by the late filing. The Court found that no reason had been assigned to justify the inordinate delay and that the delay had deprived the assessee of the opportunity to avail the statutory option under the Direct Tax Vivad se Vishwas Act, 2020 within time.
Conclusion: The revenue failed to establish sufficient cause for condonation of delay, and the delay was not condoned.