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    <description>Refusal to condone an inordinate filing delay did not give rise to a substantial question of law under Section 35G where the Tribunal had rejected the explanation as insufficient on facts. The challenge was to a discretionary factual finding, so the delay issue could not be reopened in further appeal. Separately, dismissal of the appeal for non-compliance with a subsisting pre-deposit condition could not be interfered with because the waiver order had never been set aside. An appeal filed without satisfying that condition was treated as ineffective in law, and the dismissal followed as a necessary consequence.</description>
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      <description>Refusal to condone an inordinate filing delay did not give rise to a substantial question of law under Section 35G where the Tribunal had rejected the explanation as insufficient on facts. The challenge was to a discretionary factual finding, so the delay issue could not be reopened in further appeal. Separately, dismissal of the appeal for non-compliance with a subsisting pre-deposit condition could not be interfered with because the waiver order had never been set aside. An appeal filed without satisfying that condition was treated as ineffective in law, and the dismissal followed as a necessary consequence.</description>
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