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Sufficient cause for delayed appeals against revision orders requires a credible explanation for the entire period of inaction under section 253(5). A consequential assessment order does not itself justify failure to challenge the underlying revision order within limitation. Reliance on professional assistance or a change of auditor is inadequate where it does not establish a bona fide reason for the delay, particularly if the assessee was represented in consequential reassessment proceedings. Failure to establish sufficient cause results in rejection of the delay-condonation request and dismissal of the appeal as time-barred without consideration on merits.
Sufficient cause for delayed appeals against revision orders requires a credible explanation for the entire period of inaction under section 253(5). A consequential assessment order does not itself justify failure to challenge the underlying revision order within limitation. Reliance on professional assistance or a change of auditor is inadequate where it does not establish a bona fide reason for the delay, particularly if the assessee was represented in consequential reassessment proceedings. Failure to establish sufficient cause results in rejection of the delay-condonation request and dismissal of the appeal as time-barred without consideration on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
