Condonation of extraordinary delay in re-presenting departmental...

Condonation of extraordinary delay in re-presenting departmental tax appeals requires a reasonable, plausible and bona fide explanation supported by a coherent account of the period of inaction. General assertions of administrative workload, simultaneous appeal filings, voluminous records and procedural requirements do not establish sufficient cause. Delay in re-presentation is assessed less rigorously than delay under the Limitation Act, but government departments receive no preferential treatment and must show diligence and bona fide effort. The condonation applications were dismissed, and the departmental appeals were rejected.