Condonation of delay turns on a bona fide explanation, supporting liberal discretion and merits adjudication.

Condonation of delay depends on the acceptability of the explanation rather than the period of delay. The notes state that limitation provisions should prevent dilatory conduct without defeating access to adjudication. Receipt of an appellate order by an accounts manager, followed by delayed escalation to the company until recovery proceedings, may constitute sufficient cause where supported by a director's affidavit and shown to be bona fide. The discussion supports liberal exercise of discretion to advance substantial justice and permit a merits hearing.

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Issues: Whether the delay of 712 days in filing the appeal before the Tribunal ought to have been condoned.

Analysis: Condonation depends upon the acceptability of the explanation rather than the length of delay. Limitation rules are intended to prevent dilatory conduct, not to defeat a litigant's right to seek adjudication. The explanation that the appellate order had been received by the accounts manager and was not brought to the company's notice until recovery proceedings, supported by the director's affidavit, was bona fide and constituted sufficient cause. The Tribunal should have exercised its discretion liberally to advance substantial justice and afford an opportunity of hearing on merits.

Conclusion: The delay was required to be condoned; the substantial question of law is answered in favour of the assessee and against the Revenue.

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