Sufficient explanation for the entire delay is required; an incomplete explanation led to refusal of condonation and dismissal of the appeal.

Condonation of an 894-day delay in appealing against a revision order requires a proper and satisfactory explanation covering the entire period of delay. The explanation that the assessee and its chartered accountant believed an appeal was necessary only against the consequential assessment order did not account for the further delay of nearly two years after that assessment order. The stated reasons therefore failed to constitute a sufficient explanation for the complete delay. The ITAT Mumbai did not condone the delay, and the appeal was dismissed in limine as unadmitted.

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Issues: Whether the delay of 894 days in filing the appeal against the revision order was liable to be condoned.

Analysis: An appeal filed beyond the prescribed limitation requires a proper and satisfactory explanation for the delay. The explanation that the assessee and its chartered accountant believed that an appeal was required only against the consequential assessment order did not account for the further delay of nearly two years after the assessment order was passed. The Tribunal found that the reasons furnished did not constitute a proper explanation for the entire delay.

Conclusion: The delay was not condoned and the appeal was dismissed in limine as un-admitted.

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