Liberal construction of sufficient cause permits condonation where delay is bona fide and merits should be decided.

Delay in filing an appeal may be condoned where the explanation is bona fide and discloses no deliberate inaction, negligence, or mala fides. The governing approach to "sufficient cause" is a reasonable, pragmatic, practical, and liberal interpretation, with preference for adjudication on merits rather than dismissal on technical limitation grounds. On the facts, the delay was explained by the appellant's of the Sabka Vishwas scheme and subsequent financial constraints, and the refusal to condone was set aside. The matter was remanded to the Commissioner (Appeals) for decision on merits after condonation of the 28-day delay.

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Issues: Whether the delay in filing the appeal before the Commissioner (Appeals) was supported by sufficient cause so as to warrant condonation under the proviso to Section 85(3A) of the Finance Act, 1994.

Analysis: The explanation for delay was that the appellant first awaited the benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and, after the scheme became operational, further delayed filing because of financial constraints. The delay was not found to be deliberate, mala fide, or attributable to negligence. The governing principle applied was that the expression "sufficient cause" must receive a reasonable, pragmatic, practical, and liberal interpretation, with the preference ordinarily being for disposal on merits rather than foreclosure on technical limitation grounds where the explanation is bona fide.

Conclusion: The delay was held to be sufficiently explained, the refusal to condone was set aside, and the matter was remanded to the Commissioner (Appeals) for decision on merits after condoning the delay of 28 days.

Ratio Decidendi: Where the explanation for delay is bona fide and discloses no deliberate inaction, negligence, or mala fides, "sufficient cause" for condonation must be construed liberally in favour of adjudication on merits.

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