Dismissing the appeal of the revenue the Court held that, period of limitation should not come as an hindrance to do substantial justice between the parties . However considering the facts of the case the Delay of 318 days was not condoned as the department has not explained reasonable cause . Court also observed that on an average 2000 appeals are filed by the revenue every year ,thus the Officers of the revenue should be well aware of the statutory provisions and period of limitation for filing appeals. ( L.No. 2319, 2320 of 2017 , NM 1779 1783 of 2017 dt 1-03-2018) ( AY. 2008 -09, 2009-10)