Condonation of delay requires a bona fide day-to-day explanation; departmental workload alone will not extend limitation.

Condonation of a 205-day delay in filing revision requires a satisfactory day-to-day explanation and proof of sufficient cause; a vague reference to departmental engagement in other GST matters is inadequate where it does not cover the entire period of delay. The court reiterated that condonation is a discretionary relief available only on a reasonable, bona fide, and convincing explanation, and limitation cannot be diluted on equitable grounds alone. On the facts, the supporting material was not properly placed at the earliest stage and the explanation failed to justify the full delay, so the delay was not condoned and the revision was held not maintainable.

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Issues: Whether the revisionist had shown sufficient cause to condone the delay of 205 days in filing the revision.

Analysis: The delay was not supported by a satisfactory day-to-day explanation. The material relied upon to justify the delay was not properly placed at the earliest stage, and the explanation that departmental officers were occupied with other GST proceedings did not account for the entire period of delay after the matter had already gone before the legal committee. The governing principle is that condonation of delay is a discretionary relief to be granted only where sufficient cause is shown, and not as a matter of course. In the absence of a reasonable, bona fide, and convincing explanation, the statutory limitation period cannot be diluted on equitable considerations.

Conclusion: The delay was not liable to be condoned and the revision was not maintainable.

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