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Heard on the COD applications. Learned Counsel for the appellant submits that delay was 47 days and ground of delay could be attributable to the engagement of staff  uring mandatory Audit procedure for which he received the OIA just before the due date of filing of appeal was due. Part  of the delay was also due to his own engagement in other cases for which appeal Memo for all 3 appeals could not be prepared and presented on time.