Liberal condonation of delay and natural justice required restoration of appeals for fresh adjudication.

A liberal construction of "sufficient cause" was applied for condonation of inordinate delay, because the assessee cited banking distress, seizure of assets, and lapse by its representative, with no wilful negligence or mala fides. The delay was condoned. The first appellate authority's dismissal without proper consideration of the affidavit and supporting material was treated as a denial of fair opportunity and a breach of natural justice, so the matter was restored for fresh adjudication after adequate hearing. The substantive issues were left open.

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Issues: (i) Whether the inordinate delay in filing the appeals before the first appellate authority deserved condonation on showing sufficient cause. (ii) Whether the orders of the first appellate authority required to be set aside and the matters remitted for fresh adjudication.

Issue (i): Whether the inordinate delay in filing the appeals before the first appellate authority deserved condonation on showing sufficient cause.

Analysis: The delay was explained on the basis that the assessee was under banking distress, its assets had been seized, and the lapse in filing the appeals was attributable to the then representative and circumstances beyond the assessee's control. The Tribunal applied the settled principle that the expression 'sufficient cause' must receive a liberal construction and that substantial justice prevails over technicalities where there is no wilful negligence or mala fides.

Conclusion: The delay was condoned in favour of the assessee.

Issue (ii): Whether the orders of the first appellate authority required to be set aside and the matters remitted for fresh adjudication.

Analysis: Since the first appellate authority had dismissed the appeals without proper consideration of the assessee's affidavit and supporting material, the Tribunal found a denial of fair opportunity and a breach of natural justice. As the merits had not been examined, the dispute was restored to the first appellate authority for a fresh decision after granting adequate opportunity of hearing.

Conclusion: The impugned orders were set aside and the matters were remitted for fresh adjudication.

Final Conclusion: The appeals were allowed only to the extent of condonation of delay and restoration of the matters to the first appellate authority for decision afresh, leaving the substantive disputes open.

Ratio Decidendi: 'Sufficient cause' for condonation of delay calls for a liberal and justice-oriented construction, and where a party is not guilty of wilful negligence, appellate authorities should prefer adjudication on merits over dismissal on technical grounds.

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