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“condonation of delay”

AppealsSection 249Section 24912,312 judgments

The decision most relied on for condonation of delay is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on condonation of delay

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

Balakrishnan v. M. Krishnamurthy
7 SCC 123 · 1998 · Supreme Court
368
citing judgments

The Supreme Court outlines the principles for condoning delay in filing appeals, stating that a litigant's lapse is not always a bar if the explanation is bona fide and not a dilatory strategy. Courts should show utmost consideration to suitors and prioritize substantial justice unless the delay is deliberately to gain time.

Vishin Meghani v. DCIT & Anr
398 ITR 250 · 2017 · High Court
291
citing judgments

This case is cited as an authority supporting the condonation of delay in filing income tax appeals, particularly when an assessee presents a request for such condonation.

Concord of India Insurance Co. Ltd. v. Smt. Nirmala Devi and Others
118 ITR 507 · 1979 · Supreme Court
268
citing judgments

For condoning delay, the term 'sufficient cause' must be interpreted liberally and purposively to advance justice. Delay not tainted by mala fides, gross negligence, or recklessness, and based on honestly obtained legal advice, constitutes sufficient cause.

Inder Singh v. State of Madhya Pradesh
2025 INSC 382 · 2025 · Supreme Court
267
citing judgments

Non-deliberate procedural delays caused by circumstances beyond control must be condoned in the interest of substantial justice, even if the delay is significant, such as over 1500 days.

Vedabhai v. Santaram
253 ITR 798 · 2002 · Supreme Court
262
citing judgments

When substantial justice and technical considerations are in conflict, substantial justice should be prioritized. Condoning delay requires a cautious approach without malafide or dilatory tactics, and 'sufficient cause' should be interpreted liberally to advance substantial justice.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

Judgments citing condonation of delay

DCIT 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3371/MUM/2023[2018-19]Status: DisposedITAT Mumbai24 Jan 2024AY 2018-19

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

also. Accordingly, we allowed the ground raised by the assessee i.e. ground no.1 in favour of the assessee. Revenue's Appeal Condonation of delay 19. There is a delay of 120 days in filing all the appeals by the Revenue. The ld. DR in this regard filed a letter requesting ... condonation of delay stating that the concerned AO was not in good health and therefore, could not carry out his duty fully which resulted in the delay in filing the appeal. The ld. DR accordingly prayed that there is reasonable cause for the delay which needs to be condoned. HDFC

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax-2(3)(1), Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1785/MUM/2023[2018-2019]Status: DisposedITAT Mumbai24 Jan 2024AY 2018-2019

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

also. Accordingly, we allowed the ground raised by the assessee i.e. ground no.1 in favour of the assessee. Revenue's Appeal Condonation of delay 19. There is a delay of 120 days in filing all the appeals by the Revenue. The ld. DR in this regard filed a letter requesting ... condonation of delay stating that the concerned AO was not in good health and therefore, could not carry out his duty fully which resulted in the delay in filing the appeal. The ld. DR accordingly prayed that there is reasonable cause for the delay which needs to be condoned. HDFC

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax-2(3)(1), Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1784/MUM/2023[2017-2018]Status: DisposedITAT Mumbai24 Jan 2024AY 2017-2018

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

also. Accordingly, we allowed the ground raised by the assessee i.e. ground no.1 in favour of the assessee. Revenue's Appeal Condonation of delay 19. There is a delay of 120 days in filing all the appeals by the Revenue. The ld. DR in this regard filed a letter requesting ... condonation of delay stating that the concerned AO was not in good health and therefore, could not carry out his duty fully which resulted in the delay in filing the appeal. The ld. DR accordingly prayed that there is reasonable cause for the delay which needs to be condoned. HDFC

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax-2(3)(1), Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1783/MUM/2023[2016-2017]Status: DisposedITAT Mumbai24 Jan 2024AY 2016-2017

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

also. Accordingly, we allowed the ground raised by the assessee i.e. ground no.1 in favour of the assessee. Revenue's Appeal Condonation of delay 19. There is a delay of 120 days in filing all the appeals by the Revenue. The ld. DR in this regard filed a letter requesting ... condonation of delay stating that the concerned AO was not in good health and therefore, could not carry out his duty fully which resulted in the delay in filing the appeal. The ld. DR accordingly prayed that there is reasonable cause for the delay which needs to be condoned. HDFC

Tirupati Buildings and Offices P.Ltd, New Delhi vs. ACIT, Central Circle-18, New Delhi

ITA 202/DEL/2023[2011-12]Status: DisposedITAT Delhi24 Jan 2024AY 2011-12

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 143(3)Section 153ASection 153DSection 68

assessee was dismissed by order dated 31.08.2022. 4. In the light of aforesaid facts and circumstances, reconsider it an appropriate case to condone the delay in both the appeals. Accordingly, the application for condonation of delay stands allowed. 5. The facts in brief are that original assessment in case

Tirupati Buildings and Offices P.Ltd, New Delhi vs. ACIT, Central Circle-18, New Delhi

ITA 201/DEL/2023[2009-10]Status: DisposedITAT Delhi24 Jan 2024AY 2009-10

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 143(3)Section 153ASection 153DSection 68

assessee was dismissed by order dated 31.08.2022. 4. In the light of aforesaid facts and circumstances, reconsider it an appropriate case to condone the delay in both the appeals. Accordingly, the application for condonation of delay stands allowed. 5. The facts in brief are that original assessment in case

Yashbir Malik, Sonipat vs. ITO, Ward-4, Sonipat

The appeal is allowed for statistical purpose

ITA 2728/DEL/2022[2013-14]Status: DisposedITAT Delhi24 Jan 2024AY 2013-14

Bench: Shri G.S. Pannu & Shri Anubhav Sharmaassessment Year: 2013-14

Section 143(3)

pointed out by the learned AR that there is a delay in filing of the appeal for which an application for condonation of delay is filed. On hearing upon the application for condonation of delay, it comes up that the impugned order of learned CIT(A) was passed ... light of facts before us, indicating some mental health issues of the assessee, we consider it an appropriate case to condone the delay and hear the appeal on merits. 3. Next, an additional evidence application was filed under Rule 29 and it was submitted by learned AR that

Asian Tours and Travels, Secunderabad vs. Income Tax Officer, Ward-10(1), Hyderabad

In the result, the appeal filed by the assessee is dismissed

ITA 1/HYD/2024[2013-14]Status: DisposedITAT Hyderabad23 Jan 2024AY 2013-14

Bench: Shri Laliet Kumarassessment Year: 2013-14 Asian Tours & Travels, Vs. The Income Tax Officer, Secunderabad, Ward-10(1), 9-4-212/94, Opp To Hyderabad. Railway Station, Hyderabad. Telangana – 500003. Pan : Aakfa8752H. (Appellant) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri Rohit Mujumdar, Sr.Ar. Date Of Hearing: 22/01/2024 Date Of Pronouncement: 23/01/2024

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri Rohit Mujumdar, Sr.AR
Section 139(9)Section 143(1)

weight of evidence and probabilities of case. 2. The learned Commissioner in considering the maxim ignoratia juris non excusat, while refusing to condone the delay of 2263 days without considering the facts and circumstances mentioned in the condonation petition. 3. The learned Commissioner ought to have appreciated that in view ... order. He further submitted that assessee has a good case on merit and therefore, the merit should not be pitted against the non-condonation of delay by the ld.CIT(A). 6. Per contra, the ld.DR has submitted that no evidence placed on record by the assessee to substantiate the delay

(Late) Nageswara Rao Veeramachaneni L/R Veeramachaneni Surendra Babu, Nandigama vs. Income Tax Officer, Ward-11(5), Hyderabad

In the result, the appeal of assessee in ITA No

ITA 635/HYD/2023[2010-11]Status: DisposedITAT Hyderabad23 Jan 2024AY 2010-11

Bench: Shri Laliet Kumar

For Appellant: Sri K. Sudhakar ReddyFor Respondent: Shri T. Venkanna, Sr.AR
Section 142Section 143Section 144Section 147Section 148Section 271(1)

there is a delay in service, the Appellate Authority ought to have seen that the delay is properly explained. Though separate application for condonation of delay, has not been filed, the factum of the reasons which led to the filing of the appeal, has been narrated in the grounds

(Late) Nageswara Rao Veeramachaneni L/R Veeramachaneni Surendra Babu, Nandigama vs. Income Tax Officer, Ward-11(5), Hyderabad

In the result, the appeal of assessee in ITA No

ITA 634/HYD/2023[2010-11]Status: DisposedITAT Hyderabad23 Jan 2024AY 2010-11

Bench: Shri Laliet Kumar

For Appellant: Sri K. Sudhakar ReddyFor Respondent: Shri T. Venkanna, Sr.AR
Section 142Section 143Section 144Section 147Section 148Section 271(1)

there is a delay in service, the Appellate Authority ought to have seen that the delay is properly explained. Though separate application for condonation of delay, has not been filed, the factum of the reasons which led to the filing of the appeal, has been narrated in the grounds

M/S C.I. Builders Pvt. Ltd., Bhopal vs. The DCIT 1(1), Bhopal

Appeals are dismissed

ITA 248/IND/2023[2012-13]Status: DisposedITAT Indore23 Jan 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 271(1)(c)

captioned ITAs respectively; therefore these twin-appeals are time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay accompanied by assessee’s affidavit as well as a supportive affidavit of previous counsel (Shri Ashwini Rinwa, Advocate) in both matters. The contents ... Taxmann 270 (Bombay HC) and Oracle India Pvt. Ltd. Vs. DCIT (2008) 13 DTR 372 (ITAT, Delhi), Ld. AR prayed to condone the delay in present matters. During arguments, when the Bench raised a pointed query to Ld. AR as to the period upto which the previous counsel handled assessee

M/S C.I. Builders Pvt. Ltd., Bhopal vs. The ACIT, 1(2), Bhopal

Appeals are dismissed

ITA 247/IND/2023[2010-2011]Status: DisposedITAT Indore23 Jan 2024AY 2010-2011

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 271(1)(c)

captioned ITAs respectively; therefore these twin-appeals are time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay accompanied by assessee’s affidavit as well as a supportive affidavit of previous counsel (Shri Ashwini Rinwa, Advocate) in both matters. The contents ... Taxmann 270 (Bombay HC) and Oracle India Pvt. Ltd. Vs. DCIT (2008) 13 DTR 372 (ITAT, Delhi), Ld. AR prayed to condone the delay in present matters. During arguments, when the Bench raised a pointed query to Ld. AR as to the period upto which the previous counsel handled assessee

C Ramasamy Gounder HUF, Erode vs. ITO, Ward 1(5), Tirupur

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1305/CHNY/2023[2010-11]Status: DisposedITAT Chennai23 Jan 2024AY 2010-11

Bench: Mr.Justice (Retd.) C.V. Bhadang & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1305/Chny/2023 िनधा"रण वष" / Assessment Year: 2010-11 C. Ramasamy Gounder Huf, Income Tax Officer 3/112, Puduvelliyampalayam, V. Ward 1(5), Nathakkadaiyur Kangayam, Tirupur. Erode – 638 701. [Pan: Aachc-1186-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. Arjunraj, Ca For अपीलाथ" क" ओर से/Appellant By Shri. S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri. P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 23.01.2024 घोषणा क" तारीख/Date Of Pronouncement : 23.01.2024 आदेश /O R D E R Per Manjunatha. G:

For Respondent: Shri. P. Sajit Kumar, JCIT
Section 144Section 147Section 148

preferred an appeal before the ld. CIT(A) on 24.05.2022, with a delay of 857 days. The appellant has filed a petition for condonation of delay along with reasons for delay in filing of appeal. According to the Ld. Counsel for the assessee, out of total delay of 857 days ... assessee submitted that there is a reasonable cause for not filing appeal within due date under the Act and thus, prayed for condonation of delay. The ld. CIT(A) after considering relevant petition filed by the assessee dismissed the appeal without condoning the delay by holding that, reasons given

Venkatesan Ramaiah, Chennai vs. ITO, Non Corporte Ward10(5), Chennai

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1294/CHNY/2023[2016-2017]Status: DisposedITAT Chennai23 Jan 2024AY 2016-2017

Bench: Mr.Justice (Retd.) C.V. Bhadang & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1294/Chny/2023 िनधा"रण वष" / Assessment Year: 2016-17 Venkatesan Ramaiah, Income Tax Officer #1, Rajammal Street, V. Non Corporate Ward -10(5), 6Th Floor, Wanaparthy Block, Shenoy Nagar, Chennai – 600 030 . Aayakar Bhavan, 121, M.G. [Pan: Aabpv-0386-M] Road, Chennai – 600 034. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Anand Babunath, Ca : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 23.01.2024 घोषणा क" तारीख/Date Of Pronouncement : 23.01.2024

For Appellant: Shri. Anand Babunath, CA
Section 54B

outset, we find that there is a delay of 112 days in appeal filed by the assessee, for which a petition for condonation of delay along with affidavit explaining reasons for delay has been filed. The Ld. Counsel for the assessee, referring the petition filed by the assessee submitted that ... reasons given by the appellant for not filing the appeal within due date prescribed under the Act, does come under reasonable cause for condonation of delay and thus, we condone the delay in filing of appeal and admit the appeal filed by the appellant. 5. The brief facts

Muthusamy Viknesh Kumar, Namakkal vs. ITO, Ward-1, Namakkal

In the result, appeal filed by the assessee is allowed for

ITA 1226/CHNY/2023[2010-11]Status: DisposedITAT Chennai23 Jan 2024AY 2010-11

Bench: Mr.Justice (Retd.) C.V. Bhadang & Shri Manjunatha.Gआयकरअपीलसं./I.T.A.No.1226/Chny/2023 ("नधा"रणवष" / Assessment Year: 2010-11) Mr. Muthusamy Viknesh Kumar Vs Income Tax Officer, 5/242-A,Teachers Colony, Ward-1, Namakkal-637 001. Namakkal. Pan: Agnpv 1117G (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. P.Sajit Kumar, JCITFor Respondent: 23.01.2024
Section 147Section 148Section 234

assessee submitted that the appeal filed by the assessee is time barred by 24 days for which necessary petition for condonation of delay along with affidavit explaining the reasons for the delay has been filed. The Ld. AR further submitted that the assessee could not file appeal within the time ... therefore, delay may be condoned in the interest of advancement of substantial justice. 3. The learned DR, on the other hand, strongly opposing condonation of delay petition filed by the assessee submitted that the reasons given by the assessee do not come within the ambit of reasonable and bonafide reasons

Kundapura Vyavasaya Seva Sahakari Sangha Niyamitha, Udupi vs. Income Tax Officer, Ward-1, Udupi

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1027/BANG/2023[2017-18]Status: DisposedITAT Bangalore23 Jan 2024AY 2017-18

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2017-18 M/S. Kundapura Vyavasaya Seva Sahakari Vs. Ito, Sangha Niyamita, Ward – 1, Head Office, Kundeshwara Temple Road, Udupi. Kundapura, Udupi District – 576 201, Karnataka. Pan : Aaaak 3448 D Appellant Respondent Assessee By : Shri. Akshay, Ca Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 23.01.2024 Date Of Pronouncement : 23.01.2024

For Appellant: Shri. Akshay, CAFor Respondent: Shri. V. Parithivel, JCIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Assessment Year is 2017-18. 2. There is a delay of 324 days in filing this appeal. Assessee has filed a petition for condonation of delay accompanied by affidavit of CEO of assessee society stating there in the reasons for belated filing of this appeal. The reason stated for belated ... substantial justice, the delay may be condoned and the matter may be decided on merits. 3. The learned DR strongly objected to the condonation of delay in filing this appeal. 4. We have heard the rival submissions and perused the material on record. Admittedly, there is a delay

Rajiv Kumar Singh, Meerut vs. ITO, Ward 2(2), Meerut

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2895/DEL/2023[2017-18]Status: DisposedITAT Delhi23 Jan 2024AY 2017-18

Bench: Shri Kul Bharat & Shri Pradip Kumar Kediavs. Ito Rajiv Kumar Singh Vill. Chamrodh, Tarapur, Ward – 2(2) Mawana, Meerut, Up-250 404 Meerut Pan No. Bxepr 0212 H (Appellant) (Respondent) Assessee By Shri Rohit Agarwal, C.A. Revenue By Shri Vivek Vardhan, Sr. D.R. Date Of Hearing: 23.01.2024 Date Of Pronouncement: 23.01.2024 Order Per Pradip Kumar Kedia, Am :

Section 143(3)Section 144Section 249(2)Section 249(3)

concerning Assessment Year 2017-18. 2. As per the grounds of appeal, the assessee has inter alia challenged the denial of condonation of delay in instituting the appeal before him on misconception of facts and law. 2 3. When the matter was called for hearing, the learned Counsel ... impugned first appellate order, it is seen that the CIT(A) dismissed the appeal of the assessee in limine by refusing to condone purported delay of 44 days calculated by him. The appeal was thus dismissed without adjudication of appeal on merits. The assessee on the other hand has demonstrated

Shankaraiah Telakapally, Nalgonda vs. Income Tax Officer, Ward -1, Nalgonda

In the result, the appeal of assessee is allowed for statistical purposes

ITA 655/HYD/2023[2017-18]Status: DisposedITAT Hyderabad22 Jan 2024AY 2017-18

Bench: Shri Laliet Kumarassessment Year: 2017-18 Shankaraiah Telakapalli, Vs. The Income Tax Officer, 4-10-520/Cs/1, Sainagar Ward – 1, Colony, Ward-24, Nalgonda. Nalgonda, Telangana - 508001. Pan : Alipt1315Q. (Appellant) (Respondent) Assessee By: Shri S. Phanindra, Advocate. Revenue By: Shri T. Venkanna, Sr.A.R. Date Of Hearing: 18/01/2024 Date Of Pronouncement: 22/01/2024

For Appellant: Shri S. Phanindra, AdvocateFor Respondent: Shri T. Venkanna, Sr.A.R
Section 115BSection 142(1)Section 144Section 24Section 69ASection 80CSection 80ESection 80G

have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, I allow the application for condonation of delay subject to assessee’s undertaking that he visits Goshala of his choice and treats ailing cows. Accordingly, the delay is condoned and the appeal

Balupuri Ashupuri Goswami, Mumbai vs. ITO Ward 31.1.3, Now (14.4.1., Mumbai

ITA 2360/MUM/2023[2014-2015]Status: DisposedITAT Mumbai22 Jan 2024AY 2014-2015

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Year: 2014-15

For Appellant: Shri Devendra Jain, A.RFor Respondent: Shri Ajay Singh, Sr. D.R

time barred by 124 days. The Ld. A.R. for the appellant, M/s. Balupuri Ashupuri Goswami (hereinafter referred to as ‘the assessee’) sought to condone the delay by moving an application supported with an affidavit on the grounds inter-alia that prior to the due date of filing appeal brother ... appeal was neither intentional nor willful. 2. However, on the other hand, the Ld. D.R. for the Revenue opposed the application for condonation of delay on the ground that the late filing of appeals in this case is apparently malafide due to callous attitude of the assessee and prayed

ACIT, CC-14, Delhi vs. Lakshya Consultants Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 181/DEL/2021[2005-06]Status: HeardITAT Delhi22 Jan 2024AY 2005-06

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Lalit Mohan, CAFor Respondent: Shri Subhra Jyoti Chakraborty, CIT- DR
Section 153ASection 253Section 5

Income-tax Act, 1961 [the Act, for short]. 3. The appeal is late by 1540 days. The Revenue has filed an application for condonation of delay which reads as under: 4 4. The application is supported by the following affidavit: 5. We have given thoughtful consideration to the contents ... letter requesting for condonation of delay. We are aware that the power to condone the appeal must be exercised liberally in favour of the applicant, especially where the appellant is a Government body and the exchequer is involved. For this, we draw support from the decision