Condonation of inordinate delay in tax appeals requires a credible explanation; strategic delay and prior knowledge defeated relief.

A 1217-day delay in filing an appeal against a revisional order was not condoned because the appellant failed to show sufficient cause. The explanation that it acted on legal advice and believed the input tax credit dispute could be pursued in consequential reassessment proceedings and a writ petition was rejected, as the appellant knew of the revisional order, participated in remand proceedings without objection, and challenged the matter only after adverse consequential orders. The Court held that condonation in tax matters is not subject to an automatic liberal approach and must still satisfy settled discretionary parameters; inordinate delay without a credible and satisfactory explanation cannot be excused.

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Issues: Whether the delay of 1217 days in filing the appeal against the revisional order could be condoned.

Analysis: The explanation for delay was that the appellant was under a bona fide belief, based on legal advice, that it could contest the input tax credit issue in the consequential reassessment proceedings and in the writ petition. The Court held that this explanation did not constitute sufficient cause. The appellant had knowledge of the revisional order, participated in the remand proceedings without objection, and only challenged the matter after suffering adverse consequential orders. The Court distinguished the authorities relied upon for condonation, noting that those cases involved either short delay or a satisfactorily explained absence of knowledge, whereas the present case involved an inordinate delay with no convincing justification. The Court further held that condonation in tax matters is not governed by a blanket liberal approach and must still satisfy the established parameters for judicial discretion.

Conclusion: The delay was not liable to be condoned and the application for condonation was rejected.

Ratio Decidendi: Inordinate delay can be condoned only on a credible and satisfactory explanation showing sufficient cause, and a liberal approach does not extend to excusing unexplained or strategically delayed challenges.

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