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SC upheld the HC orders condoning delay in filing tax appeals by the Revenue but found the HC's reasoning deficient and insufficiently detailed; the SC held that the HC must examine the facts pleaded in applications for condonation of delay with particularity before final disposal. Although no serious procedural or substantive error warranted interference with the condonation orders, in the interest of justice the SC directed the Revenue to pay costs quantified at Rs.25,000 to the respondent/assessees in each tax appeal before the HC and admonished that future condonation applications be decided on a detailed, fact-sensitive rationale.
SC upheld the HC orders condoning delay in filing tax appeals by the Revenue but found the HC's reasoning deficient and insufficiently detailed; the SC held that the HC must examine the facts pleaded in applications for condonation of delay with particularity before final disposal. Although no serious procedural or substantive error warranted interference with the condonation orders, in the interest of justice the SC directed the Revenue to pay costs quantified at Rs.25,000 to the respondent/assessees in each tax appeal before the HC and admonished that future condonation applications be decided on a detailed, fact-sensitive rationale.
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