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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the assessee had shown sufficient cause to condone the inordinate delay in filing the appeals before the first appellate authority and, consequently, whether the appeals could be entertained on merits.
Analysis: The delay in filing the appeals before the first appellate authority was found to be more than 10 years in one appeal and more than 11 years in the other, and no proper day-to-day explanation for such delay was furnished. The distinction between normal delay and inordinate delay was noted, and leniency was held to be appropriate only in cases of ordinary delay. In view of the absence of sufficient cause, and relying on the approach adopted in recent delay-condonation jurisprudence, the request to overlook the delay was declined.
Conclusion: The delay was not condoned and the dismissal of the appeals by the first appellate authority was upheld, against the assessee and in favour of the Revenue.
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