Pragmatic condonation of delay accepted where labour disruption caused late filing, and the appeal was restored for fresh hearing.

A six-day delay in filing the appeal was condoned after the Tribunal accepted that a labour had closed the factory for about a month, causing the delay. The expression "sufficient cause" was applied pragmatically and in a justice-oriented manner, without insisting on a technical explanation for each day's delay. The order dismissing the appeal as time-barred was set aside, and the matter was remanded to the Commissioner (Appeals) for fresh decision after granting a personal hearing.

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Issues: Whether the six-day delay in filing the appeal before the Commissioner (Appeals) ought to be condoned, and whether the matter should be restored for fresh decision.

Analysis: The delay was stated to have occurred because of a labour problem that led to closure of the factory for about a month. The Tribunal applied the principle that the expression "sufficient cause" must be construed with pragmatism and in a justice-oriented manner, rather than by a technical insistence on explaining every day's delay.

Conclusion: The delay was condoned, the order dismissing the appeal as time-barred was set aside, and the matter was remanded to the Commissioner (Appeals) for fresh decision after granting a personal hearing.

Final Conclusion: The assessee obtained restoration of the appeal on the question of limitation, and the dispute was sent back for reconsideration on merits.

Ratio Decidendi: "Sufficient cause" for condonation of delay must be assessed pragmatically and with a justice-oriented approach, not by a technical insistence on explaining each day's delay.

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