Condonation of delay in first appeal fails where no credible explanation or supporting material shows sufficient cause.

An inordinate delay in filing a first appeal could not be condoned where the assessee produced no application, affidavit, or corroborative material explaining the default. The record showed prolonged inaction and no evidence of diligence, bona fides, or steps taken during the delay period, so the statutory test of sufficient cause was not met. On that basis, the first appellate authority was justified in refusing to entertain the appeal as time-barred, and the challenge to the limitation-based dismissal failed.

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Issues: Whether the assessee had shown sufficient cause for condonation of an inordinate delay in filing the first appeal and whether the dismissal of the appeal as time-barred was justified.

Analysis: The assessment order was communicated to the assessee and the appeal before the first appellate authority was filed after an extraordinarily long delay. The record did not contain any application, affidavit, or corroborative material explaining the delay, nor any material showing diligence, bona fides, or steps taken during the period of default. Applying the settled principles governing condonation of delay, the absence of a credible explanation and the prolonged inaction meant that the statutory requirement of sufficient cause was not satisfied. The delay therefore could not be excused, and the first appellate authority was justified in refusing to entertain the appeal on limitation.

Conclusion: The refusal to condone the delay and the dismissal of the appeal as time-barred were upheld. The assessee's challenge failed.

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