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Issues: Whether the delay in filing the appeal under section 260A of the Income-tax Act, 1961 deserved condonation under sections 5 and 12 of the Limitation Act, 1963.
Analysis: The governing principle is that condonation of delay depends on the existence of sufficient cause, not on the length of the delay. The cause shown must be examined on its own facts, with a liberal approach where the explanation is bona fide and there is no gross negligence or deliberate inaction. The time spent in obtaining certified copies is excludable, and the period spent in bona fide pursuing a review remedy can also support exclusion on principles analogous to section 14 of the Limitation Act, 1963, where the litigant acted with due diligence and good faith. On the facts, the appellant showed that it had not been informed of the Tribunal's orders, promptly sought certified copies upon gaining knowledge, and pursued review in good faith before filing the appeal.
Conclusion: The delay was held to be sufficiently explained and was condoned, in favour of the assessee.
Ratio Decidendi: Delay in filing an appeal may be condoned where the appellant establishes a bona fide, diligent, and satisfactory explanation amounting to sufficient cause, including time spent in pursuing a remedy in good faith.