https://www.taxtmi.com/caselaws?id=784068 The dominant issue was whether "sufficient cause" existed under s.5 Limitation Act to condone a 2262-day delay in filing a statutory appeal against a penalty order. Applying the liberal construction mandated by SC in Katiji and giving effect to SC's COVID-19 limitation extension excluding 15.03.2020 to 28.02.2022, the HC held the tribunal erred in treating the appellant's conduct as total negligence and in expecting daily monitoring of a digital portal during the pandemic. Denial of a merits challenge to a substantial penalty on account of non-deliberate delay was held unjust and contrary to preservation of substantive rights. The substantial question of law was answered in favour of the appellant and the appeal was disposed of accordingly. en-us Wed, 24 Dec 2025 00:00:00 +0530 Mon, 29 Dec 2025 08:56:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784068 The dominant issue was whether "sufficient cause" existed under s.5 Limitation Act to condone a 2262-day delay in filing a statutory appeal against a penalty order. Applying the liberal construction mandated by SC in Katiji and giving effect to SC's COVID-19 limitation extension excluding 15.03.2020 to 28.02.2022, the HC held the tribunal erred in treating the appellant's conduct as total negligence and in expecting daily monitoring of a digital portal during the pandemic. Denial of a merits challenge to a substantial penalty on account of non-deliberate delay was held unjust and contrary to preservation of substantive rights. The substantial question of law was answered in favour of the appellant and the appeal was disposed of accordingly. Case-Laws Central Excise Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784068