Sufficient cause for tax revision delay must be shown by credible diligence, not a bare mistaken belief about limitation.

Inordinate delay in filing a tax revision will not be excused unless the applicant shows sufficient cause through a credible and diligent explanation. A claimed mistaken belief about the limitation period was rejected because the record showed earlier belated appeals, dismissal for non-deposit after opportunities, and long inactivity before the revision was filed. The court treated the limitation under the Goa Value Added Tax Act, 2005 as clear and found that the revision was lodged only after notice of provisional freezing of accounts. Delay was therefore not condoned, the application was rejected, and the connected revision also stood disposed of.

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Issues: Whether the inordinate delay of 2 years and 300 days in filing the tax revision application could be condoned on the basis of bona fide belief and asserted sufficient cause.

Analysis: The applicant sought condonation on the footing that it had proceeded under a mistaken belief as to the period of limitation for revision before the Court. The chronology on record showed that the first appeal itself was filed belatedly, the second appeal was dismissed for non-deposit after opportunities, and no meaningful steps were taken for nearly three years thereafter. The limitation under the Goa Value Added Tax Act, 2005 for a revision against the Tribunal's order was treated as clear, and the revision was filed only after notice of provisional freezing of accounts. On these facts, the explanation offered did not establish sufficient cause, and the conduct of the applicant showed lack of diligence.

Conclusion: The delay was not condoned and the application was rejected.

Final Conclusion: The revision proceedings did not survive once condonation was declined, and the connected revision was also disposed of accordingly.

Ratio Decidendi: Inordinate delay in a tax revision will not be condoned unless the applicant establishes sufficient cause by a credible and diligent explanation; a claimed mistaken belief, unsupported by the surrounding conduct and chronology, is insufficient.

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