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Issues: Whether the delay in filing the revenue appeal should be condoned.
Analysis: The explanation for delay was based on later instructions from the Board to file appeals in matters where the decision in Jawahar Mills had been followed. The relevant appellate order had not followed that decision, and the department had already accepted the order-in-appeal and decided not to challenge it within time. Subsequent administrative instructions were held not to constitute sufficient cause for failure to present the appeal within the prescribed period.
Conclusion: The delay was not condoned and the application was rejected. The appeal was also rejected.