Condonation of delay requires a full explanation for the entire delay; hardship alone cannot justify a late revision petition.

Sufficient cause for condonation of delay in a revision application under the Indian Income-tax Act requires an explanation covering the entire period of delay. The SC noted that although the assessee had a plausible grievance on merits, the application gave no explanation for the delay between the Tribunal's order and the filing of the revision petition. A bare appeal to hardship was held insufficient to meet the statutory limitation requirement. The refusal to entertain the revision application was therefore upheld against the assessee.

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Issues: Whether the assessee had shown sufficient cause for condonation of the delay in filing the revision application under section 33A(2) of the Indian Income-tax Act, 1922.

Analysis: The right to seek revision was examined in the context of the statutory limitation under section 33A(2). Although the assessee had a plausible grievance on the merits, the application disclosed no explanation for the period of delay between the Tribunal's order and the filing of the revision petition. In considering condonation, the explanation must account for the whole period of delay, and a bare invocation of hardship cannot substitute for a satisfactory explanation.

Conclusion: The assessee failed to establish sufficient cause for condonation of delay, and the refusal to entertain the revision application was upheld against the assessee.

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