Condonation of delay in tax appeal granted where portal upload prevented effective notice and a fair chance to respond.

Delay in filing the tax appeal was condoned where notices and orders had been uploaded only in the portal section meant for additional notices and orders, which materially impaired the taxpayer's practical opportunity to notice and respond. The explanation for the late filing was accepted as genuine, and the fact that the tax demand had already been substantially discharged supported hearing the appeal on merits. Refusing to entertain the appeal in these circumstances would have denied a fair opportunity, so the appeal was directed to be taken on record and decided in accordance with law.

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Issues: Whether the delay in filing the tax appeal deserved condonation and whether the appeal should be taken on record for decision on merits.

Analysis: The challenge arose from an assessment order and the dismissal of the statutory appeal as time-barred. The Court found that the notices and orders were uploaded only in the portal section meant for additional notices/orders, which deprived the petitioner of a practical opportunity to notice and respond to them. It further accepted that the explanation for the delayed appeal was genuine and noted that the tax demand had already been substantially discharged. In these circumstances, refusal to hear the appeal on merits would result in denial of a fair opportunity.

Conclusion: The delay of 25 days was condoned and the appeal was directed to be taken on record and decided on merits in accordance with law.

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