Dismissing the appeal of the Revenue the Court held, that the lack of sincerity, or rather complete absence thereof on the part of the Revenue in this case was glaringly conspicuous by its having not even filed an application seeking condonation of this colossal delay of about three years in filing these appeals, that too despite having faced a situation where it had to withdraw the earlier appeals and was granted liberty to file afresh. The circumstances enumerated in the affidavits dated May 17, 2023 of the Revenue sounded merely an “excuse” and not an “explanation” of delay. None of the dates and stages recorded could be accepted by any stretch of imagination as disclosure of factors beyond the control of the Revenue and thereby sufficient cause which led to delay in filing the appeals. The Revenue in its affidavits dated May 17, 2023 did not even disclose the date of filing of those earlier appeals. From records of the Registry it was found that those earlier appeals were filed on February 9, 2021, i. e., much subsequent to expiry of the limitation period. Even if the covid-19 lockdown were kept in mind, it started on March 15, 2020 much later than expiry of limitation period (which expired on August 9, 2019). The Revenue had failed to disclose sufficient cause for not having filed these appeals during the period from August 9, 2019 to March 15, 2020. The delay in filing appea is not condoned. The Finance Act, 2010 ([2010] 323 ITR (St.) 1)   (AY.2009-10,2014-15)