Sufficient Cause for Delay Requires a Pleaded Explanation; Unexplained Inaction Leaves Revenue Appeal Time-Barred Under Limitation Law

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....Condonation of inordinate delay requires a pleaded and substantiated sufficient cause; filing before a court without territorial jurisdiction and subsequent administrative movement of papers, without a pleaded pandemic-related impediment, do not establish it. Gross negligence, deliberate inaction and unexplained delay undermine finality and certainty under limitation law, while delay may prejudice the opposing side. On these principles, the revenue's condonation request was rejected and its appeal was treated as barred by limitation.....