Condonation of delay requires a concrete explanation; vague claims of file movement do not displace limitation rights.

Delay in filing an appeal under Section 260A of the Income-tax Act was not condoned because the revenue failed to show sufficient cause for 498 days' delay. The court found that the application was a cyclostyled proforma with no concrete facts, no disclosure of file movement, and no explanation for the relevant period. It reaffirmed that while delay may receive some latitude in governmental matters, liberal construction cannot replace a reasonable and adequate explanation. The expiry of limitation creates a substantive right in the opposite party, and vague references to official procedure or hierarchy are insufficient.

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Issues: Whether the revenue had shown sufficient cause for condonation of 498 days' delay in filing the appeal under Section 260A of the Income-tax Act, 1961.

Analysis: The application disclosed no concrete facts explaining the delay and was found to be a cyclostyled proforma with only the number of days inserted. The Court reiterated that although delay may, in some situations, be viewed with latitude, especially in governmental matters, liberal construction cannot override the requirement of a reasonable and adequate explanation. The expiry of limitation creates a substantive right in favour of the opposite party, and such right cannot be displaced on vague assertions of official procedure, bona fides, or the general plea that the matter moved through hierarchy. In the absence of any disclosure of the movement of the file or any explanation for the period of delay, no sufficient cause was made out.

Conclusion: The application for condonation of delay was rejected; the delay was not condoned.

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