Limitation for appeal is not extended by rectification proceedings; inordinate delay needs bona fide sufficient cause and due diligence.

Pendency of rectification proceedings does not suspend the limitation period for filing an appeal, and an inordinate delay can be condoned only on a credible, bona fide explanation showing sufficient cause and due diligence. A bare assertion of adviser lapse, without supporting material, is insufficient where the delay is extreme. On that basis, the appeal remained time-barred and the refusal to condone the delay was upheld.

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Issues: Whether the extraordinary delay of about 2000 days in filing the appeal before the first appellate authority was liable to be condoned on the ground of pendency of rectification proceedings and alleged lapse on the part of the tax advisor.

Analysis: The explanation for the prolonged delay was confined to the filing of a rectification application and the assertion that the assessee was awaiting its disposal. The pendency of rectification proceedings does not suspend or extend the statutory period for filing an appeal. A litigant is required to act with due diligence and cannot avoid the consequences of limitation on the basis of an unsubstantiated claim of advisor negligence, particularly when no supporting material is produced. For condonation of such an inordinate delay, a credible and bona fide explanation constituting sufficient cause is necessary, and gross negligence or inaction does not meet that standard.

Conclusion: The delay was not liable to be condoned and the dismissal of the appeal as time-barred was upheld.

Ratio Decidendi: Pendency of rectification proceedings does not stop limitation for filing an appeal, and an inordinate delay can be condoned only on a credible showing of sufficient cause supported by bona fide conduct and due diligence.

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