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Issues: Whether the departmental appeals filed with a delay of 109 days deserved condonation on the basis of the application and affidavit filed by the Wealth-tax Officer.
Analysis: The delay was substantial and the explanation had to cover the entire period of default. The application accounted only for the short period immediately before filing and gave no satisfactory explanation for the earlier delay. The accompanying affidavit was held to be unsupported by proper evidence, lacking a reliable source of knowledge, and based largely on conjecture rather than proved facts. The asserted cause for the delay was therefore not accepted as sufficient cause.
Conclusion: Condonation of delay was refused and the departmental appeals were not entertained as time-barred.