Condonation of delay in tax appeal accepted where State gave a reasonable administrative explanation and revenue stakes were significant.

Delay of 721 days in filing a tax appeal was condoned because the State's explanation covered internal administrative processing, departmental opinions and approvals, forwarding to the Finance Department, and drafting delays in the Government Pleader's office. The Court noted that the delay was not wholly unexplained, the claim of heavy workload in the Government Pleader's office was not disputed, and the dispute involved substantial and recurring revenue implications. In limitation matters involving State litigation, the Court accepted that reasonable explanation and significant revenue impact may justify some latitude, and the application succeeded subject to costs.

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Issues: Whether the State had shown sufficient cause for condonation of a delay of 721 days in filing the tax appeal.

Analysis: The delay was explained by reference to internal administrative processing, obtaining departmental opinions and approvals, forwarding the matter to the Finance Department, and the time consumed in the Government Pleader's office for drafting and filing the appeal. The Court noted that the objectionable delay was not left wholly unexplained, that the assertion regarding heavy workload in the Government Pleader's office was not disputed, and that the dispute involved a substantial and recurring tax effect. In the context of limitation governing State litigation, the Court accepted that some latitude may be shown where the explanation is reasonable and the matter involves significant revenue consequences.

Conclusion: The delay was condoned, subject to payment of costs, and the application succeeded.

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