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Condonation of delay requires sufficient cause, but appeals raising matters requiring examination on merits should not be excluded solely because of a technical limitation. The material explains that a pedantic refusal to consider reasons for delay may undermine merits-based adjudication, particularly where the assessee challenged denial of exemption during processing under section 143(1). Applying this approach, the delayed appeals were treated as deserving condonation, the refusal was set aside, and the matters were restored to the Commissioner (Appeals) for determination on merits.
Condonation of delay requires sufficient cause, but appeals raising matters requiring examination on merits should not be excluded solely because of a technical limitation. The material explains that a pedantic refusal to consider reasons for delay may undermine merits-based adjudication, particularly where the assessee challenged denial of exemption during processing under section 143(1). Applying this approach, the delayed appeals were treated as deserving condonation, the refusal was set aside, and the matters were restored to the Commissioner (Appeals) for determination on merits.
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