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    <description>Delay in filing an appeal before the Commissioner (Appeals) was held condonable on the showing of sufficient cause under the proviso to section 85(3) of the Finance Act, 1994. The explanation that the party first sought legal advice and later pursued the proper appellate remedy was accepted, and a mere presumption about the date of service of the impugned order, unsupported by contrary evidence or postal verification, was found insufficient to defeat condonation. The statutory appeal was treated as filed in time and restored to the Commissioner (Appeals) for decision on merits.</description>
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      <description>Delay in filing an appeal before the Commissioner (Appeals) was held condonable on the showing of sufficient cause under the proviso to section 85(3) of the Finance Act, 1994. The explanation that the party first sought legal advice and later pursued the proper appellate remedy was accepted, and a mere presumption about the date of service of the impugned order, unsupported by contrary evidence or postal verification, was found insufficient to defeat condonation. The statutory appeal was treated as filed in time and restored to the Commissioner (Appeals) for decision on merits.</description>
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