Condonation of delay - 353 days in filing the appeal before the...

Condonation of delay - 353 days in filing the appeal before the Tribunal - The sufficient cause within the contemplation of the limitation provision must be a cause which is beyond the control of the party invoking the aid of the provisions. The cause for the delay in filing the appeal which by due care and attention could have been avoided cannot be a sufficient cause within the meaning of the limitation provision.. In the present case, the reasons for delay in filing the appeal is not sufficiently explained by the assessee and it shows that the delay was due to negligence and inaction on the part of assessee which cannot be condoned. - AT

---