Supreme Court upholds ITAT refusal to condone delay

The Supreme Court upheld the ITAT’s and High Court’s approach denying condonation of delay in filing an appeal where the assessee’s delay resulted from gross negligence and inadequate grounds were advanced to establish “sufficient cause.” The judgment emphasises that judicial discretions to condone delay are not to be exercised mechanically: claimants must demonstrate bona fide reasons — not mere lapses of counsel, unexplained inordinate delay, or attempt to rely on routine administrative advice. The ruling reiterates established principles: (i) the length of delay, (ii) reasons for delay, (iii) bona fides of appellant, and (iv) prejudice caused to the other side, are relevant and must be weighed cumulatively. The decision sends a clear message to taxpayers and advising professionals about diligence in appeal filings, record keeping, and timely prosecution of remedies. For tax practitioners the case underscores need for contemporaneous proof when seeking condonation (communications, proof of service/receipt, medical or other cogent causes), and it reaffirms the judiciary’s insistence on procedural discipline to prevent undue litigation and calendar congestion.