Bona fide compliance delay can be condoned when default is not wilful and obstacles were beyond control.

Delay in post-merger compliance may be condoned where the applicant shows bona fide efforts, correspondence with revenue authorities on stamp duty formalities, and disruption caused by the Covid-19 period. The Tribunal accepted that the default was not wilful and that the stated circumstances were beyond the applicant's control, so the 451-day delay was condoned and time for compliance was extended.

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Issues: Whether the delay of 451 days in complying with the Tribunal's earlier orders should be condoned and time extended for compliance.

Analysis: The application was founded on the asserted inability to complete post-merger compliance and stamp duty-related formalities within the stipulated period. The reasons placed before the Tribunal showed that the applicant had taken steps to pursue compliance, but was hindered by circumstances stated to be beyond its control, including the disruption caused by the Covid-19 period and the correspondence with the revenue authorities regarding stamp duty and related documents. On that basis, the Tribunal accepted that the default was not wilful and that valid reasons existed for the delay.

Conclusion: The delay was condoned and the time for compliance was extended.

Ratio Decidendi: Delay in compliance may be condoned where the applicant shows bona fide efforts and valid reasons beyond its control, and the default is not wilful.

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