Substantial justice justified condonation of delay where internal approvals delayed filing and merits required consideration.

Delay in filing a tax appeal was explained by the chronology of internal approvals and inter-departmental processing, supported by affidavits, and was not treated as intentional. The text states that refusing condonation would have prevented consideration of the substantive tax issue concerning the applicable rate on fungicides, pesticides, herbicides and weedicides. On that basis, substantial justice was treated as the governing consideration and the 496-day delay was condoned.

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Issues: Whether the delay of 496 days in filing the tax appeal should be condoned.

Analysis: The delay was explained through the chronology of events and subsequent affidavits showing that approval and processing were undertaken through different departments before the appeal could be filed. The appeal raised a substantive question on the applicable rate of tax on fungicides, pesticides, herbicides and weedicides, and refusing condonation would have deprived the applicant of an to seek consideration on merits. In the circumstances, the delay was not treated as intentional and substantial justice was held to justify condonation.

Conclusion: The delay of 496 days was condoned.

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