Condonation of delay requires a justice-oriented, liberal approach; refusal to condone the appeal delay was set aside.

A request for condonation of a 166-day delay in filing an appeal before the ITAT should be considered on a justice-oriented and liberal basis. The refusal to condone the delay by the Tribunal and the High Court was set aside, the delay was condoned, and the appeal was directed to be decided in accordance with law.

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Issues: Whether the delay of 166 days in filing the appeal before the Income Tax Appellate Tribunal ought to have been condoned.

Analysis: The delay was declined to be condoned by the Tribunal and the High Court. The Court held that both fora ought to have adopted a justice-oriented and liberal approach while considering the request for condonation of delay.

Conclusion: The delay was condoned, the impugned orders refusing condonation were set aside, and the appeal was directed to be decided in accordance with law.

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