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Issues: Whether the delay in filing the appeals against the refund orders should be condoned.
Analysis: The appeals were filed after the statutory period of three months had expired. The explanation offered was that further information was sought from the adjudicating authority before filing the appeals, but those requests were made only after the limitation period had already run out. The appellate authority had considered the explanation and found no satisfactory or convincing cause for the delay, and no material was shown to disturb that finding. The principle that delay may be liberally condoned where sufficient cause is shown did not assist the appellants on these facts.
Conclusion: The delay was not liable to be condoned, and the dismissal of the appeals was upheld in favour of Revenue.
Final Conclusion: The challenge to the refusal to condone delay failed, leaving the original dismissal of both appeals undisturbed.
Ratio Decidendi: Delay in filing an appeal cannot be condoned merely because the appellant sought additional information after limitation had expired; a satisfactory showing of sufficient cause is required.