https://www.taxtmi.com/caselaws?id=442139 Delay in filing an appeal under Section 260A of the Income-tax Act was not condoned because the revenue failed to show sufficient cause for 498 days' delay. The court found that the application was a cyclostyled proforma with no concrete facts, no disclosure of file movement, and no explanation for the relevant period. It reaffirmed that while delay may receive some latitude in governmental matters, liberal construction cannot replace a reasonable and adequate explanation. The expiry of limitation creates a substantive right in the opposite party, and vague references to official procedure or hierarchy are insufficient. en-us Wed, 23 Aug 2023 00:00:00 +0530 Mon, 30 Oct 2023 12:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442139 Delay in filing an appeal under Section 260A of the Income-tax Act was not condoned because the revenue failed to show sufficient cause for 498 days' delay. The court found that the application was a cyclostyled proforma with no concrete facts, no disclosure of file movement, and no explanation for the relevant period. It reaffirmed that while delay may receive some latitude in governmental matters, liberal construction cannot replace a reasonable and adequate explanation. The expiry of limitation creates a substantive right in the opposite party, and vague references to official procedure or hierarchy are insufficient. Case-Laws Income Tax Wed, 23 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442139