Strict limitation on condonation of delay bars an appeal where no sufficient cause is shown for extraordinary lateness.

A strict statutory outer limit governed condonation of delay, and the appellate authority could not enlarge that period. The appellant had knowledge of the demand proceedings years earlier, had participated in the investigation, and failed to show sufficient cause for the extraordinary delay. On those facts, the delay was not condoned, the appeal was held time-barred, and the challenge to the demand proceedings failed.

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Issues: Whether the appeal, filed after a long delay, could be entertained by condoning the delay and whether the appellant had shown sufficient cause for such condonation.

Analysis: The appeal was filed years after the appellant had knowledge of the adjudication. The record showed that the appellant had participated in the investigation, had knowledge of the demand proceedings at least in 2012, and had not established any convincing reason for not pursuing the matter within the statutory period. The Tribunal noted that the appellate authority had no power to condone delay beyond the period permitted by law, and the explanation offered did not constitute sufficient cause for condoning the extraordinary delay.

Conclusion: The delay was not condoned and the appeal was not maintainable on limitation; the finding was against the assessee and in favour of the Revenue.

Final Conclusion: The order rejecting the appeal on limitation was upheld, and the challenge to the demand proceedings failed.

Ratio Decidendi: Where the statute prescribes a strict outer limit for condonation of delay, the appellate authority cannot enlarge that period, and an explanation that does not establish sufficient cause cannot justify condonation of extraordinary delay.

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