The assessee filed an appeal before the Tribunal with a delay of 1797 days along with an application for condonation supported by an affidavit explaining the circumstances leading to the delay. The Tribunal, without properly considering the reasons assigned or examining whether “sufficient cause” was made out, rejected the application and dismissed the appeal as time-barred without entering into the merits. The High Court held that although delay cannot be condoned mechanically and must be supported by sufficient cause, the merits of a case cannot be thrown out solely on technical grounds of limitation when substantial justice is at stake. A liberal approach is required where refusal to condone delay would undermine adjudication on merits. Since the assessee had placed adequate material showing reasonable and sufficient cause for the delay, the rejection by the Tribunal was not justified. Accordingly, the delay was condoned and the matter was remanded back to the Tribunal for decision on merits. Reliance was placed on Inder Singh v. State of Madhya Pradesh (2025) INSC 382, and Mool Chandra v. UOI (2025) 1 SCC 625.