Full Judgment
1. Heard both sides. There is a delay of 261 days in preferring the above appeal before the Tribunal against the impugned order of the Commissioner (Appeals) [before whom also, there was a delay of more than 9 months, which was not condoned]. No satisfactory explanation has been given by the assessees for the delay. Therefore, I decline to condone the delay. As a result, COD application and stay application are dismissed. Consequently, the appeal is dismissed as time-barred.