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Issues: Whether the assessee had shown sufficient cause for condonation of a delay of 353 days in filing the appeal.
Analysis: The explanation for delay was found to be contradictory and unsupported by material. The reasons disclosed for the delay were inconsistent, no medical record was produced for the alleged illness, and the asserted lack of communication with the auditor was not satisfactorily established. The conduct did not inspire confidence as a bona fide and diligent effort to prosecute the appeal within limitation.
Conclusion: The delay was not condoned, and the appeal remained unadmitted.