Before addressing the grounds, it is necessary to address the delay of 306 days pointed out by the registry. The assessee had filed a condonation of delay application explaining the delay. It is seen that the appeal had come up for hearing on earlier occasion (26th Sept., 2019) and considering the contents of the application, it was considered to be not sufficient and complete and the counsel was required to file a revised condonation of delay application. The revised condonation of delay application was stated to have been filed on 1st Oct., 2019 was not found on record when the appeal next came up for hearing on 10th Oct., 2019. Thereafter, on the next date of hearing, it was adjourned on the request of the learned senior Departmental Representative. Ultimately, the appeal came up for hearing on 19th Nov., 2019.