Sufficient cause requires cogent evidence; inordinate delay and negligence defeat condonation, leaving underlying merits unexamined.

Condonation of a 1,797-day delay requires a sufficient cause supported by cogent material; liberal construction of limitation provisions does not dispense with that condition. Explanations based on non-receipt of notices, reliance on a tax consultant, COVID-19 disruption and lapse of memory after office resumed were treated as insufficient to account for the entire delay. Negligence, inactivity, lack of diligence and inordinate delay remain relevant barriers to condonation. Because the delay was not condoned, the appeals were not admitted and the underlying assessment merits were not examined.

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Issues: Whether the assessee had shown sufficient cause to condone the inordinate delay in filing the appeals before the first appellate authority and before the Tribunal.

Analysis: The appeals were delayed by 1797 days. The explanation offered, namely non-receipt of notices, reliance on the tax consultant, COVID-19 disruption and lapse of memory after resumption of office, was found unsupported by cogent material and insufficient to explain the entire delay. The order relied on the principle that while limitation provisions may be construed liberally, the existence of sufficient cause remains a condition precedent, and negligence, inactivity, want of diligence, or inordinate delay cannot be ignored. The merits of the assessment were not examined because the delay itself barred admission.

Conclusion: The delay was not condoned and the appeals were not admitted on merits. The assessee's challenge failed.

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