The main legal point established in the judgment is the need for a liberal, pragmatic, justice-oriented, non-pedantic approach while dealing with an application for condonation of delay.

R. Sudhakar, J.

1. The above Tax Case (Appeals) are filed by the assessees, as against the order of the Income Tax Appellate Tribunal dated 17.04.2014, declining to condone the delay of 1100 days, raising the following substantial questions of law:

"1. Is not reasoning of the Tribunal failing to condone the delay of 1100 days in filing the appeal before it, is perverse and contrary to law?

2. Whether on facts and circumstances of the case, the Appellate Tribunal was right in dismissing the appeal on the point of limitation without appreciating the reasons stated in the affidavit filed by the appellant?

3. Whether the Appellate Tribunal is correct in not considering the "sufficient cause" for the delay which had been explained by the assessee in filing the appeal with condonation of delay?

4. Whether the finding of the Tribunal is perverse especially after admission of the main case and after granting interim relief dismissed the main case in condonation application by overlooking the earlier decision of another Bench?

5. Whether on the facts and circumstances of the case, the Tribunal was right in not considering the submission made by the counsel for the appellant at the time of argument?"

2. The brief facts relating to the above batch of appeals are as follows:

On 10.1.2008, search was conducted in terms of Section 132 of the Income Tax Act at the business place of the appellants. During the course of search, 432 documents, account books and papers were seized from the registered office of the business concern of the appellants. On 26.8.2008, the properties belonging to the appellants in Kocthiparai Village were attached by the respondent department. On 29.9.2008, notice under Section 153A of the Income Tax Act was issued for block assessment proceedings in respect of the searched persons. On 24.11.2008 it appears that the appellants had made a representation requesting to release the original documents so as to sell the property and pay the dues to the respondent. Further, in response to the notice, the appellants have filed their return of income on 05.08.2009 admitting their income for each assessment year, however, the admitted tax has not been paid.

3. After scrutinising the return of income filed and after affording opportunity to the appellants, the Assessing Officer passed an order of assessment by making additions in respect of all the above appellants. The Assessing Officer also levied interest and penalty.

4. Aggrieved by the order of assessment, the appellants/assessees filed appeals before the Commissioner of Income Tax (Appeals), who, by order dated 27.10.2010 after following the decisions of this Court in the case of S.Alagirisamy V. Income Tax Officer reported in 296 ITR 43 and Commissioner of Income Tax V. Smt.G.A.Samanthakamani reported in 259 ITR 215, dismissed the appeals in limine, on the ground that the appellants have not paid taxes on the admitted income. According to the assessees that between January and April, 2010, they have paid certain amount towards admitted tax.

5. Aggrieved by the orders of the Commissioner of Income Tax (Appeals), the assessees pursued the matter before the Income Tax Appellate Tribunal by filing appeals along with petitions to condone the delay in filing the appeals. The details of the appeals filed by the appellants are as follows:

S.No.	I.T.A.No.	Name of the Assessee	Number of days delay
1	2293 of 2013	Mrs. P.S. Rajeswari	1100
2	2294 of 2013	Mrs. P.S. Rajeswari	1100
3	2295 of 2013	E.V.Perumalsamy Reddy	1127
4	2296 of 2013	E.V.Perumalsamy Reddy	1127
5	2297 of 2013	E.V.Perumalsamy Reddy	1127
6	2298 of 2013	M/s.EVP Estates and Properties Development Limited, Chennai.	1127
7	2299 of 2013	M/s.EVP Estates and Properties Development Limi