Sufficient cause for condonation should be assessed by continuity of events, not pedantic day-to-day gaps; application allowed.

Section 119(2)(b) permits condonation of delay where a satisfactory explanation shows sufficient cause; the assessment requires coherent continuity of events rather than a pedantic day-to-day chronology. Authorities must apply a liberal, justice-oriented and pragmatic test to the explanation; refusing relief solely on limitation without testing continuity and sufficiency of cause is unsupportable. The impugned refusal was set aside and the application for condonation allowed, with a direction to decide the underlying Form-10B on merits within a specified timeframe.

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Issues: Whether the authority erred in refusing to condone the delay in filing Form-10B under Section 119(2)(b) of the Income-tax Act, 1961.

Analysis: The statutory power under Section 119(2)(b) permits condonation of delay where a satisfactory explanation establishing sufficient cause is furnished. The requirement is not strictly for a day-to-day chronology but for a coherent continuity of events which, when read meaningfully, constitutes a sufficient cause within the statutory ambit. Authorities should avoid a pedantic or mechanical approach; instead a liberal, justice-oriented and pragmatic assessment of the explanation is appropriate. The authority's strict insistence on a day-to-day account and dismissal on the sole ground of limitation, without applying the statutory test of sufficient cause to the continuity of events presented, renders the refusal unsustainable.

Conclusion: The impugned order is set aside; the application for condonation of delay is allowed and the authority is directed to decide the Form-10B on merits in accordance with law within two months from communication of the order.

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