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    <title>1997 (12) TMI 448 - CEGAT, MUMBAI</title>
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    <description>Delay of 47 days in filing the appeal before the Commissioner (Appeals) was condoned because two orders on the same issue had been received close together and the assessee, a small-scale unit, could reasonably have confused them and failed to act in time. The explanation was accepted on the principle that substantial justice should prevail over technical considerations, and the appeal was allowed with the matter remanded for decision on merits according to law.</description>
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      <description>Delay of 47 days in filing the appeal before the Commissioner (Appeals) was condoned because two orders on the same issue had been received close together and the assessee, a small-scale unit, could reasonably have confused them and failed to act in time. The explanation was accepted on the principle that substantial justice should prevail over technical considerations, and the appeal was allowed with the matter remanded for decision on merits according to law.</description>
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