Liberal construction of sufficient cause justified condonation of delay where detention and service issues explained the belated income-tax appeal.

Delay in filing an income-tax appeal may be condoned where the appellant shows sufficient cause and bona fide inability to act within time. Applying a liberal construction of "sufficient cause" to advance substantial justice, the explanation that the assessment order and demand notice were served on an unauthorised person, that the managing director alone could sign the appeal papers, and that she was under detention was accepted on the supporting material. The 52-day delay was therefore treated as explained, and the matter was restored for decision on merits.

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Issues: Whether the delay of 52 days in filing the appeal before the Commissioner of Income Tax (Appeals) should be condoned.

Analysis: The appeal was filed beyond the prescribed period under section 249 of the Income-tax Act, 1961. The explanation offered was that the assessment order and demand notice were served on an unauthorised person, the managing director alone was competent to sign the appeal papers, and she was under detention during the relevant period. The Court applied the settled principle that the expression "sufficient cause" requires a liberal construction to advance substantial justice and that delay should not be refused condonation when the explanation shows bona fides and absence of deliberate inaction. On the materials produced, including supporting evidence of detention, the delay was found to be explained by sufficient cause.

Conclusion: The delay was condoned and the matter was restored to the Commissioner of Income Tax (Appeals) for adjudication on merits in favour of the assessee.

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