Applicability of rule of limitation in respect of appeal filed after an inordinate delay without reasonable cause

RELEVANT PARAGRAPH 4.3 Coming to the general proposition regarding con-donation of delay, the learned counsel relied on a number of cases, which have already been summarised. In the case of Shakuntala Devi (supra), the Honourable Supreme Court held that liberal construction should be placed on the words “sufficient cause” provided that no negligence, inaction or lack of bona fide is imputable to the assessee. In this case, negligence is apparent when after taking the relevant plea before the lower authorities, the assessee chose not to file appeal before the Tribunal after filing a...