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Issues: Whether the delay in filing the appeal deserved condonation on the showing of sufficient cause.
Analysis: The notice and assessment proceedings were duly served, and the explanation offered for the belated challenge was found unconvincing. The authorities below had declined to condone the delay after rejecting the account given for non-filing within time. On the record, no material was shown to establish a credible explanation for the delay, nor was any perversity demonstrated in the exercise of discretion by the appellate authorities.
Conclusion: The refusal to condone the delay was upheld, and the appeal failed.
Ratio Decidendi: Interference with a refusal to condone delay is unwarranted where no sufficient cause is established and the discretionary finding is not shown to be perverse.