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Issues: Whether the delay of 389 days in seeking to set aside the self-operating order rejecting the appeal should be condoned.
Analysis: The application for condonation was unsupported by particulars as to when and how the Revenue became aware of the dismissal and why the office objections were not removed within time. The explanation was found to be vague and lacking bona fides. The Court relied on the principle that government departments are bound by limitation and must show a reasonable and acceptable explanation for delay, and noted that the explanation advanced reflected negligence and callousness rather than diligence.
Conclusion: The delay was not condoned.