Condonation of delay in tax appeal upheld where concurrent findings showed no sufficient cause and no substantial question of law.

Condonation of delay was refused because the assessee had knowledge of the demand at the latest on receipt of the Section 245 communication and by filing the revision under Section 264, yet filed the appeal much later without satisfactorily explaining the intervening delay. The HC held that the concurrent findings of substantial delay and absence of sufficient cause were supported by the record and showed no perversity or legal infirmity. As a result, no substantial question of law arose under Section 260A, the refusal to condone delay was upheld, and the impugned orders were sustained.

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Issues: Whether the assessee showed sufficient cause for condonation of delay in filing the appeal against the intimation under Section 143(1), and whether interference was warranted under Section 260A.

Analysis: The return was processed under Section 143(1) and a demand arose. The record showed that, at the latest, the assessee had knowledge of the demand upon receipt of the communication under Section 245 and by filing the revision under Section 264. The appeal to the Commissioner (Appeals) was nevertheless filed much later, and the intervening delay was not satisfactorily explained. The appellate authorities concurrently found that the delay was substantial and that no sufficient cause was made out. Those findings were based on the chronology and material on record, and no perversity or legal infirmity was demonstrated to justify interference in the jurisdiction under Section 260A.

Conclusion: The refusal to condone the delay was upheld, and no substantial question of law arose in favour of the assessee.

Final Conclusion: The impugned orders were sustained, and the appeal failed.

Ratio Decidendi: Concurrent factual findings rejecting condonation of delay, when supported by the record and free from perversity, do not give rise to a substantial question of law under Section 260A.

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