Liberal construction of sufficient cause supports condonation of delay, with unexamined disputes restored for fresh appellate adjudication.

Section 253(5) permits delayed appeals to be admitted where sufficient cause is shown, and the expression was applied in a liberal, justice-oriented manner on the facts of business closure, access difficulties and delayed knowledge of the orders. The delay in filing the appeals was therefore condoned. Because the first appellate authority had not examined the disputes on merits, the matters were restored for fresh adjudication, preserving both parties' opportunity to contest the additions and penalty on merits.

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Issues: (i) Whether the delay in filing the appeals before the Commissioner (Appeals) deserved to be condoned. (ii) Whether, after condoning the delay, the matters should be sent back for fresh adjudication on merits.

Issue (i): Whether the delay in filing the appeals before the Commissioner (Appeals) deserved to be condoned.

Analysis: Section 253(5) of the Income-tax Act, 1961 empowers the Tribunal to admit an appeal after the prescribed period where sufficient cause is shown. The expression "sufficient cause" was applied in a liberal and justice-oriented manner, consistent with the settled approach governing limitation provisions. The explanation offered by the assessee was examined against the surrounding facts, including the closure of the business premises, the difficulty in obtaining access to the digital filing mechanism, and the circumstances in which the orders came to be known.

Conclusion: The delay in filing the appeals was condoned, in favour of the assessee.

Issue (ii): Whether, after condoning the delay, the matters should be sent back for fresh adjudication on merits.

Analysis: Since the first appellate authority had not examined the disputes on merits, the proper course was to restore both matters for a fresh decision. The Tribunal also noted that condonation would only afford an opportunity to contest the additions and penalty on merits, without prejudicing either side.

Conclusion: The matters were remanded to the Commissioner (Appeals) for fresh adjudication on merits, in favour of the assessee.

Final Conclusion: The appeals succeeded only to the extent of condonation of delay and restoration of the matters for a de novo decision by the first appellate authority.

Ratio Decidendi: The expression "sufficient cause" for condonation of delay must receive a liberal construction where refusal would defeat substantial justice, and if the merits have not been examined by the first appellate authority, restoration for fresh adjudication is appropriate.

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