Inordinate delay in tax revision petitions requires full explanation; unexplained gaps and routine file movement are insufficient for condonation.

Inordinate delay in filing a sales tax revision petition requires a credible, continuous explanation for the entire period. An affidavit that leaves long unexplained gaps, including more than one year after receipt of the impugned order and another extended gap after an alleged change of Law Officers, does not satisfy the standard for condonation. Routine file movement is not a sufficient ground for such delay. The condonation application was rejected and the delay was not condoned.

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Issues: Whether the delay of 847 days in filing the sales tax revision petition should be condoned.

Analysis: The affidavit filed in support of condonation did not explain a substantial part of the delay. The chronology showed long unexplained gaps, including a period of more than one year after receipt of the impugned order and another long interregnum after the alleged change of Law Officers. Routine movement of files was found to be no satisfactory explanation for such inordinate delay, and the reasons disclosed were held to be insufficient even on a minimal scrutiny.

Conclusion: The delay was not condoned and the application for condonation was rejected.

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