Delay in filing appeal requires demonstration of sufficient cause; inadequate explanations led to non-condonation and dismissal.

Assessee sought condonation of an 822-day delay in filing an appeal, relying on alleged deficient advice from consultants and internal efforts to engage local tax officials. The governing standard requires demonstration of 'sufficient cause' for delay; the record of prior audits, completed earlier assessments, and multiple earlier appeals indicated the assessee's familiarity with the appellate process. Applying that legal standard to the facts, the explanations were held inadequate to establish sufficient cause, and the delay was not condoned, resulting in dismissal of the appeal in favour of the Revenue.

---

---

Issues: Whether the delay of 822 days in filing the appeal before the Commissioner of Income Tax (Appeals) for assessment year 2020-2021 should be condoned.

Analysis: The assessee relied on lack of proper advice from consultants and the secretary's attempts to engage local tax officials as reasons for the delay. The record shows prior audits, completed assessments in earlier years, and multiple earlier appeals by the assessee, indicating familiarity with the appellate process. The lower authority recorded the assessee's explanations and applied the governing standard that delay can be condoned only on demonstration of sufficient cause. Applying that standard to the facts, the explanations were held to be inadequate to demonstrate a sufficient cause for the prolonged delay.

Conclusion: The delay of 822 days is not condoned; the appeal is dismissed and the result is in favour of the Revenue.

---