Sufficient cause for delayed revision must be assessed liberally when delay follows bona fide pursuit of another remedy.

Section 33A(2) required the Commissioner to apply his mind to whether the assessee had shown sufficient cause for filing a revision petition beyond time; refusal of condonation without such consideration was improper. The expression "sufficient cause" had to be construed liberally and pragmatically, especially where the delay arose from the bona fide pursuit of another remedy in the same assessment dispute, and the assessee was not required to file a parallel proceeding merely as a safeguard. The rejection of condonation was therefore unsustainable, and the matter was remitted for reconsideration of delay and the revision petition on the merits of sufficient cause.

---

---

Issues: Whether the Commissioner was bound to consider whether sufficient cause was made out for condoning the delay in filing the revision petition under section 33A(2) of the Indian Income-tax Act, 1922, and whether the rejection of condonation without such consideration was sustainable.

Analysis: Under section 33A(2), the Commissioner could entertain a revision presented after the prescribed period only if he was satisfied that the assessee was prevented by sufficient cause from making the application in time. A proper application of mind to the question of sufficient cause was therefore obligatory. The order impugned disclosed no real consideration of that question. The assessee had been pursuing remedies in relation to the same assessment dispute and was not obliged to file a parallel proceeding merely to guard against an adverse result in the pending proceedings. The expression "sufficient cause" was also required to be approached with a liberal and practical construction, particularly where the delay was linked to bona fide pursuit of another available remedy.

Conclusion: The rejection of condonation was unsustainable, and the matter had to be remitted to the Commissioner for reconsideration of delay and the revision petition on the merits of sufficient cause.

---