Condonation of delay requires bona fide and diligent explanation; inordinate delay was not excused under the VAT review limitation rule.

Inordinate delay in filing a review application under the Haryana Value Added Tax Act, 2003 was not condoned because the explanation did not account for the full period of default and lacked bona fides and diligence. The court reiterated that "sufficient cause" requires a non-negligent, credible explanation, and that while a liberal approach may apply to short delays, a stricter standard is warranted for substantial delay. On that basis, the delay of 505 days was held not to be justified.

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Issues: Whether the delay of 505 days in filing the review application under the Haryana Value Added Tax Act, 2003 was liable to be condoned.

Analysis: The review application was subject to a limitation period of 180 days. The explanation for the delayed filing was that the point regarding completion of assessment within a reasonable time had not been pressed earlier and was noticed only after subsequent remand proceedings. The delay was substantial and the explanation did not account for the entire period of default. The Court held that condonation of delay is not to be granted mechanically, and that the expression sufficient cause requires a bona fide and non-negligent explanation. Reliance was placed on the principle that while a liberal approach may be adopted for short delays, a stricter approach is warranted where the delay is inordinate.

Conclusion: The delay was not shown to be supported by sufficient cause and was rightly not condoned.

Ratio Decidendi: Inordinate delay cannot be condoned on a casual or negligent explanation, and sufficient cause must show bona fides and diligence.

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