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    <description>Conflicting material on service of an ex parte assessment order prevented a mechanical refusal to condone delay in filing the first appeal. The record showed inconsistency between the departmental report and the service certificate on who was served and on the date of service, including a version that service was made on a person who was not a partner of the firm. Because these factual contradictions were not properly reconciled, the appellate and revisional authorities&#039; rejection of the explanation for a delay of more than two years could not be sustained. The matter required fresh reconsideration, and &quot;sufficient cause&quot; in limitation matters was to be construed liberally and in a justice-oriented manner.</description>
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      <link>https://www.taxtmi.com/caselaws?id=163447</link>
      <description>Conflicting material on service of an ex parte assessment order prevented a mechanical refusal to condone delay in filing the first appeal. The record showed inconsistency between the departmental report and the service certificate on who was served and on the date of service, including a version that service was made on a person who was not a partner of the firm. Because these factual contradictions were not properly reconciled, the appellate and revisional authorities&#039; rejection of the explanation for a delay of more than two years could not be sustained. The matter required fresh reconsideration, and &quot;sufficient cause&quot; in limitation matters was to be construed liberally and in a justice-oriented manner.</description>
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