Condonation of delay requires credible diligence and bona fides; prolonged unexplained inaction resulted in rejection of the request.

Condonation of delay requires a liberal, justice-oriented approach, but an inordinate delay requires strict scrutiny of diligence, bona fides and the adequacy of the explanation. The article notes that reliance on an earlier representative's inaction and death was not credible because the power of attorney was executed after limitation had expired. Unexplained pre-pandemic delay, lack of diligence after appointing the representative, defective authorisation documents and prolonged inaction before assessing and appellate authorities indicated gross negligence and absence of bona fides. The delay was therefore not condoned.

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Issues: Whether the delay of 2376 days in filing the appeal should be condoned.

Analysis: Although delay applications require a liberal and justice-oriented approach, an inordinate delay demands strict scrutiny of the party's conduct, diligence, bona fides and the sufficiency of the explanation. The explanation based on the inaction and subsequent death of an earlier power-of-attorney holder was not credible, since that power of attorney was executed long after limitation had expired. The assessee also failed to explain the pre-pandemic delay, did not demonstrate diligence after appointment of the earlier representative, and relied on an inadmissible power of attorney and affidavit for the subsequent representative. The prolonged inaction before the assessing and appellate authorities further established gross negligence and absence of bona fides.

Conclusion: The delay was not condoned.

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