Delay in filing appeals-unsupported administrative excuses found avoidable, so appeals barred by limitation and dismissed.

Delay of 297 days in filing appeals was considered; justification based on seasonal staff engagement, change of Secretary, and non-receipt of orders was unsupported by corroborative evidence. Electronic notices were issued and the assessee responded to the initial notice but then remained non-responsive, indicating casual and negligent prosecution. Applying principles requiring examination of conduct, bona fides and whether normal care could have avoided the delay, the record shows the delay was avoidable and not a sufficient cause for condonation; consequently the appeals are barred by limitation and dismissed.

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Issues: Whether the delay of 297 days in filing appeals should be condoned and the appeals admitted for adjudication on merits, or whether the appeals are barred by limitation.

Analysis: The delay is admitted and the reasons advanced relate to seasonal engagement of staff, change of Secretary, and alleged non-receipt of appellate orders until a recovery notice. The record shows electronic notices were issued and the assessee responded to the first notice but remained non-responsive thereafter. The asserted administrative and operational difficulties were unsupported by corroborative evidence and routine internal changes and staff engagements do not demonstrate absence of due diligence. Established principles require examination of conduct, bona fides, and whether delay could have been avoided by exercising normal care; the facts show casual and negligent prosecution of the matter and distinguish the authority relied upon by the appellant.

Conclusion: The delay is not a sufficient cause for condonation; the appeals are barred by limitation and are dismissed.

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