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Issues: Whether the assessee had shown sufficient cause to justify condonation of a delay of 840 days in filing the appeal before the first appellate authority.
Analysis: The explanation for delay was founded on the alleged non-communication of the assessment outcome by the assessee's chartered accountant. The Tribunal noted that the assessee was registered on the e-filing portal, the assessment proceedings were known to it, and no convincing material was placed to show diligence over the prolonged period of default. The Tribunal also applied the settled principle that a litigant cannot remain inactive and then shift the entire blame to counsel to excuse inordinate delay.
Conclusion: The delay was not condoned and the dismissal of the appeal in limine by the first appellate authority was upheld.