Condonation of delay fails where a later administrative instruction cannot justify reopening an accepted appellate order.

Delay in filing the appeal was not condoned because the Revenue failed to show sufficient cause. The explanation based on a later administrative instruction to file appeals in matters allegedly covered by an earlier decision was insufficient, since the impugned order had not followed that prior decision and the order-in-appeal had already been accepted without challenge within limitation. A subsequent internal direction could not reopen a matter already closed on merits or justify excusing the delay. The application for condonation was rejected and the appeal was not entertained.

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Issues: Whether the Revenue had shown sufficient cause for condonation of delay in filing the appeal, and consequently whether the appeal could be entertained.

Analysis: The delay was sought to be justified on the basis of later instructions from the Board to file appeals in matters said to be covered by a prior decision. The impugned order had not followed that prior decision, and the Revenue had already ed the order-in-appeal and decided not to challenge it within time. A subsequent administrative instruction could not, by itself, constitute sufficient cause for reopening a matter already closed on merits and for excusing the delay.

Conclusion: The application for condonation of delay was rejected, and the appeal was not entertained.

Final Conclusion: The Revenue failed to establish sufficient cause for the delayed filing, so the challenge to the order-in-appeal was declined at the threshold.

Ratio Decidendi: A later administrative direction, without more, does not amount to sufficient cause for condoning delay where the party had already accepted the order and chosen not to appeal within limitation.

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