Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appeal.
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....Sufficient cause for condoning inordinate delay in a revenue income-tax appeal requires a credible explanation demonstrating bona fides and due diligence. Liberal construction of the limitation standard does not excuse negligence, inaction, departmental workload, difficulty locating records, or unexplained delay after appeal papers are finalised. The duration of delay may be relevant, but the adequacy of the explanation remains decisive. Where substantial delay persists even after exclusion of a limitation extension and the applicant provides only excuses, condonation is unavailable. Failure to establish sufficient cause results in dismissal of the condonation application and the appeal as time-barred.....
TaxTMI