Delay condonation denied when section 154 proceedings did not explain the unexplained gap before appeal filing.

Delay condonation was refused where the only explanation for late filing was pursuit of a section 154 remedy, because that petition had been disposed of much earlier and no explanation covered the long gap before the appeal was filed. The reliance on exclusion of the pandemic period did not cure the remaining unexplained delay. The refusal to condone the delay was therefore upheld and the appeal was dismissed.

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Issues: Whether the delay in filing the appeal before the first appellate authority deserved condonation.

Analysis: The only explanation for the delay was that the assessee was pursuing the remedy under section 154. The petition under section 154 had already been disposed of much earlier, yet no explanation was offered for the long interval between that disposal and the filing of the appeal. The plea based on exclusion of the pandemic period also did not account for the remaining unexplained delay.

Conclusion: The refusal to condone the delay was upheld and the appeal was dismissed.

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