Delay condoned as Jurisdictional aspect takes precedence

In a strong reaffirmation of substantive justice, the Court held that dismissal of appeal on limitation without examining a jurisdictional challenge is legally unsustainable. 

It emphasized that where the very foundation of assessment is questioned, such as improper sanction under Section 151, procedural barriers cannot foreclose adjudication. The Court adopted a liberal approach to condonation, recognising the death of the authorised representative as a valid and compelling cause, especially within the faceless regime. 

The ruling reinforces that jurisdictional defects strike at the root and must be examined first, even if procedural delays exist.