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Issues: Whether the delay in filing the appeal against the Commissioner (Appeals)' order should be condoned.
Analysis: The appellants had pursued a revision application before the Government under a bona fide belief as to the correct remedy, and the record showed that time during the delay period was spent in pursuing that course. The delay was not treated as so long as to defeat the appeal, and the interests of justice were considered to favour a liberal approach.
Conclusion: The delay was condoned and the application was allowed.