Delay in filing appeal due to unclear statutory provisions is not a valid excuse to seek condonation

CST & VAT : Where assessee against assessment order filed appeal before Appellate Commissioner late by 836 days and sought condonation of delay contending that when Assessing Officer passed assessment order law was not clear and it was only when Tribunal rendered its judgment in case of Reliance Industries that interpretation of statutory provisions became clearer and upon coming to know of such judgment it preferred appeal, explanation rendered for condonation of delay was not sufficient