Condonation of delay requires a complete explanation for the entire period; unsupported and incomplete reasons failed here.

Delay in filing the assessee's appeals was not condoned because the application lacked supporting affidavits and did not explain when the appeals were to be filed, why the assessee believed they had been filed, or the circumstances of the lapse. Even on the assessee's own version, knowledge of non-filing arose earlier, yet the appeals were filed about two months later with no explanation for that period. The governing principle applied was that delay must be explained for the entire period and condonation is available only on a satisfactory showing of sufficient cause.

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Issues: Whether the inordinate delay in filing the assessee's appeals against the appellate order should be condoned on the facts pleaded.

Analysis: The application for condonation was unsupported by affidavits from the stated counsel and did not satisfactorily explain when the appeal was to be filed, how the assessee assumed that appeals had been filed, or the circumstances of the alleged lapse. Even on the assessee's own case, knowledge of non-filing arose around the time the connected matters were heard, yet the present appeals were filed only after about two months with no explanation for that period. The governing principle applied was that delay must be explained for the whole period and that a request for condonation can be allowed only where sufficient cause is shown. The cited authorities were distinguished on the footing that they do not dispense with the requirement of a complete and satisfactory explanation for the delay in every case.

Conclusion: The delay was not properly or satisfactorily explained and was not condoned.

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