Condonation of delay requires a specific, credible explanation and a valid affidavit; vague government assertions were insufficient.

Condonation of delay in filing a Revenue cross-objection requires a specific, credible explanation supported by a valid affidavit. Vague assertions that an officer was occupied with sensitive matters and litigation were held insufficient, especially where no concrete facts explained the delay. The supporting affidavit was also rejected as defective because it lacked proper attestation, identification, and valid administration of oath, so it could not be treated as a proper affidavit. The law of limitation was applied equally to the government authority, and the out-of-time cross-objection was not admitted.

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Issues: Whether the Revenue's cross-objection filed beyond the prescribed period could be admitted on the basis of the explanation and affidavit tendered in support of condonation of delay.

Analysis: The cross-objection was filed after substantial delay. The explanation offered was that the concerned officer was preoccupied with sensitive matters and litigation, but no specific facts were given to show the nature of the engagement or why the statutory filing could not be made in time. The purported affidavit was found defective, as it lacked proper attestation, identification and valid administration of oath, and therefore could not be treated as a proper affidavit. The Court held that an application for condonation must disclose a specific and credible cause, and that vague assertions by a government officer do not amount to sufficient cause. The law of limitation applies equally to government authorities.

Conclusion: The delay was not condoned and the Revenue's cross-objection was dismissed as barred by limitation, in favour of the assessee.

Final Conclusion: The decision reaffirms that procedural delay can be excused only on a specific, bona fide and legally supportable showing, and that defective affidavits and generalised explanations are insufficient for condonation.

Ratio Decidendi: Condonation of delay requires a valid affidavit and a specific, credible explanation constituting sufficient cause; vague and unsupported assertions, particularly by a public authority, do not justify admission of an out-of-time filing.

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