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“reasonable cause”

PenaltySection 273BSection 273B7,285 judgments

The decision most relied on for reasonable cause is Ashok Pai v. CIT (292 ITR 11), cited in 812 judgments on BharatTax.

Leading authorities on reasonable cause

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

Balakrishnan v. M. Krishnamurthy
7 SCC 123 · 1998 · Supreme Court
368
citing judgments

The Supreme Court outlines the principles for condoning delay in filing appeals, stating that a litigant's lapse is not always a bar if the explanation is bona fide and not a dilatory strategy. Courts should show utmost consideration to suitors and prioritize substantial justice unless the delay is deliberately to gain time.

Akhil Bhartiya Prathmik Shikshak Sangh Bhawan Trust v. ADIT
115 TTJ 419 · 2008 · ITAT
292
citing judgments

Penalty under Section 272A(1)(d) for non-compliance with a notice issued under Section 142(1) is not leviable when the assessee demonstrates a reasonable cause for such non-compliance. The decision defines what constitutes 'reasonable cause' in this context.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

CIT v. K.S.P. Shanmugavel Nadai and Ors.
153 ITR 596 · 1985 · High Court
171
citing judgments

Where a reasonable cause for delay in filing an appeal exists, the period of delay may not be a relevant factor for condonation. The court has condoned even substantial delays, such as nearly 21 years, based on the presence of a reasonable cause.

People Education and Economic Development Society (PEEDS) v. ITO
100 ITD 87 · 2006 · ITAT
121
citing judgments

When substantial justice and procedural technicalities are in conflict, especially in cases involving non-deliberate delay, the cause of substantial justice must be prioritized. The opposing party cannot claim a vested right to benefit from injustice due to such delays.

Commissioner of Income Tax v. Noida Toll Bridge Co. Ltd.
262 ITR 260 · 2003 · High Court
121
citing judgments

Journal entries for accepting or repaying loans and deposits, without any actual cash transaction, do not violate the provisions of Section 269SS or Section 269T of the Income Tax Act. Consequently, such transactions do not attract penalties under Section 271D or Section 271E.

Judgments citing reasonable cause

ACIT, Central Circle-2(3), Pune vs. Mantra Properties, Varanasi

In the result, the appeal filed by the Revenue is allowed

ITA 2116/PUN/2024[2017-18]Status: DisposedITAT Pune23 Sept 2026AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 148Section 269SSection 271DSection 274

above discussion, it is proved that that the assessee has violated the provisions of S. 269SS of the Act without having any reasonable cause within the meaning of S.273B of the Act, making itself liable for levy of penalty u/s. 271D of the Act. I, therefore, levy a penalty

Sivasakthi Ravindran, Chennai vs. DCIT, Non Corporate Circle 10, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 794/CHNY/2025[2011-12]Status: DisposedITAT Chennai16 Sept 2026AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.794/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Sivasakthi Ravindran, Vs. The Deputy Commissioner Of 50, Taylors Road, Kilpauk, Income Tax, Chennai 600 010. Non Corporate Circle 10(1), Chennai. [Pan:Aarpr2655K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 31.07.2025 घोषणा की तारीख /Date Of Pronouncement : 21.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: NoneFor Respondent: Ms. Gouthami Manivasagam, JCIT

appeal”, the assessee mentioned “Yes”, but, however, no petition for condonation of delay was filed either manually or uploaded in the portal stating reasonable cause which really prevented the assessee in not filing the appeal in time. Further, we note that the assessee has not signed Form 36 and grounds

Rikab Chand, Tiruvallur vs. Income Tax Officer, Non Corp Ward -10(3) Chennai, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 2465/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Sept 2026AY 2016-17

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.2465/Chny/2025 िनधा8रण वष8 /Assessment Year: 2016-17

For Appellant: NoneFor Respondent: Ms. M. Subashri, Addl. CIT (virtual)
Section 147

appeared. The assessee has neither explained the delay in filing the appeal nor appeared for hearing. In the absence of any reasonable cause being shown, we are not inclined to condone the delay. Accordingly, the appeal is dismissed as time-barred. 4. In the result, the appeal filed

High Voit Electicals P Ltd, Mumbai vs. Income Tax Officer Ward -1, Palghar

In the result, the appeal is dismissed

ITA 4465/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2026AY 2013-14

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 142(1)Section 143(3)Section 147Section 250Section 271(1)(b)

make any compliance of this notice. The AO has mentioned that on one occasion the Assessee furnished its reply but failed to furnish any reasonable cause with evidence. Hence reply of the assessee was not acceptable. Therefore, the AO was satisfied that assessee has failed to comply to statutory notices ... issued without any reasonable cause and accordingly, imposed a penalty of Rs. 10,000/- for each failure totaling to Rs.20,000/- for the above defaults. 5.3 During the appellate proceedings, the CIT(A) has gone through all the submissions and materials available in the office. The facts of the case

High Voit Electicals P Ltd, Mumbai vs. Income Tax Officer Ward -1, Palghar

In the result, the appeal is dismissed

ITA 4464/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2026AY 2013-14

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 142(1)Section 143(3)Section 147Section 250Section 271(1)(b)

make any compliance of this notice. The AO has mentioned that on one occasion the Assessee furnished its reply but failed to furnish any reasonable cause with evidence. Hence reply of the assessee was not acceptable. Therefore, the AO was satisfied that assessee has failed to comply to statutory notices ... issued without any reasonable cause and accordingly, imposed a penalty of Rs. 10,000/- for each failure totaling to Rs.20,000/- for the above defaults. 5.3 During the appellate proceedings, the CIT(A) has gone through all the submissions and materials available in the office. The facts of the case

High Voit Electicals P Ltd, Mumbai vs. Income Tax Officer Ward -1, Palghar

In the result, the appeal is dismissed

ITA 4463/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2026AY 2013-14

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 142(1)Section 143(3)Section 147Section 250Section 271(1)(b)

make any compliance of this notice. The AO has mentioned that on one occasion the Assessee furnished its reply but failed to furnish any reasonable cause with evidence. Hence reply of the assessee was not acceptable. Therefore, the AO was satisfied that assessee has failed to comply to statutory notices ... issued without any reasonable cause and accordingly, imposed a penalty of Rs. 10,000/- for each failure totaling to Rs.20,000/- for the above defaults. 5.3 During the appellate proceedings, the CIT(A) has gone through all the submissions and materials available in the office. The facts of the case

High Voit Electicals P Ltd, Mumbai vs. Income Tax Officer Ward -1, Palghar

In the result, the appeal is dismissed

ITA 4462/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2026AY 2013-14

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 142(1)Section 143(3)Section 147Section 250Section 271(1)(b)

make any compliance of this notice. The AO has mentioned that on one occasion the Assessee furnished its reply but failed to furnish any reasonable cause with evidence. Hence reply of the assessee was not acceptable. Therefore, the AO was satisfied that assessee has failed to comply to statutory notices ... issued without any reasonable cause and accordingly, imposed a penalty of Rs. 10,000/- for each failure totaling to Rs.20,000/- for the above defaults. 5.3 During the appellate proceedings, the CIT(A) has gone through all the submissions and materials available in the office. The facts of the case

Sls Developers, Ranga Reddy vs. ITO., Ward-8(1), Hyderabad

ITA 895/HYD/2025[2018-19]Status: DisposedITAT Hyderabad17 Jun 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Sri P. Vinod, AdvocateFor Respondent: Sri Siva Prasad SV, Sr. AR

condonation of delay and submitted that, the assessee could not explain reasons for delay in filing appeal before the Tribunal with 'sufficient and reasonable cause' and submitted that, the reasons explained by the assessee are general in nature. He, therefore, submitted that, the delay condonation petition filed by the assessee ... appeal before the Tribunal within the prescribed date, are vague and general in nature and the assessee has failed to show 'sufficient and reasonable cause' for condonation of delay. We further observe that, during the course of assessment proceedings and during the appellate proceedings before the learned CIT(A) also

Yuvradhani Agro & Developers Pvt Ltd, Yavatmal vs. ITO Ward-1, Yavatmal

In the result, the appeal of the assessee is allowed

ITA 47/NAG/2026[2017-18]Status: DisposedITAT Nagpur26 Mar 2026AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.47/Nag/2026 Assessment Year : 2017-18 Yuvradhani Agro & Developers Vs. Income Tax Officer, Pvt Ltd. Ward-1, Yavatmal G.No 68 Ralegaon, Yavatmal 445402, Maharashtra Pan: Aaacy5622R Appellant Respondent

For Appellant: Ms.Alfiya RozieFor Respondent: Shri Surjit Kumar Saha
Section 144Section 148Section 69A

provide reasonable opportunity of hearing to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause, failing which the ld.CIT(A) shall be free to proceed in accordance with law. Findings of the CIT(A)/NFAC are set aside

Trambak Raghunath Kale, Amravati vs. Income Tax Officer Ward 3, Amravati

In the result, appeal is dismissed

ITA 30/NAG/2026[2020-2021]Status: DisposedITAT Nagpur26 Mar 2026AY 2020-2021

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.30/Nag/2026 Assessment Year : 2020-21 Trambak Raghunath Kale, Vs. Income Tax Officer, Congress Nagar, Camp Road, Ward-3, Amravati Amravati-444602, Maharashtra Pan: Bbbpk6461L Appellant Respondent

For Appellant: NoneFor Respondent: Shri Surjit Kumar Saha
Section 143(3)Section 250(6)

issues as contemplated u/s.250(6) of the Act. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause, failing which the ld.CIT(A) shall be free to proceed in accordance with law. Findings of the CIT(A)/NFAC are set aside

Md. Babar Ali, Malda vs. I.T.O., Ward - 3(1), Malda

In the result, the appeal filed by the assessee in ITA No

ITA 3175/KOL/2025[2020-2021]Status: DisposedITAT Kolkata20 Mar 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 234ASection 250Section 271BSection 273BSection 44A

rejected the profit result flowing from the same books. 6. Opportunity to Produce Books: That the non-production of books earlier was due to reasonable cause (reliance on tax consultant/lack of technical knowledge). The Appellant prays for an opportunity to produce the books of accounts before the Hon'ble Tribunal ... facts by confirming the penalty of Rs. 1,17,930/- levied under Section 271B of the Income Tax Act. 1961 2. Existence of Reasonable Cause (Section 273B): That the Ld. CIT(A) failed to appreciate that the appellant had a "reasonable cause" for the delay in filing the audit report

Md. Babar Ali, Malda vs. I.T.O., Ward - 3(1), Malda

In the result, the appeal filed by the assessee in ITA No

ITA 3174/KOL/2025[2020-2021]Status: DisposedITAT Kolkata20 Mar 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 234ASection 250Section 271BSection 273BSection 44A

rejected the profit result flowing from the same books. 6. Opportunity to Produce Books: That the non-production of books earlier was due to reasonable cause (reliance on tax consultant/lack of technical knowledge). The Appellant prays for an opportunity to produce the books of accounts before the Hon'ble Tribunal ... facts by confirming the penalty of Rs. 1,17,930/- levied under Section 271B of the Income Tax Act. 1961 2. Existence of Reasonable Cause (Section 273B): That the Ld. CIT(A) failed to appreciate that the appellant had a "reasonable cause" for the delay in filing the audit report

Md. Babar Ali, Malda vs. I.T.O., Ward - 3(1), Malda

In the result, the appeal filed by the assessee in ITA No

ITA 3173/KOL/2025[2020-2021]Status: DisposedITAT Kolkata20 Mar 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 234ASection 250Section 271BSection 273BSection 44A

rejected the profit result flowing from the same books. 6. Opportunity to Produce Books: That the non-production of books earlier was due to reasonable cause (reliance on tax consultant/lack of technical knowledge). The Appellant prays for an opportunity to produce the books of accounts before the Hon'ble Tribunal ... facts by confirming the penalty of Rs. 1,17,930/- levied under Section 271B of the Income Tax Act. 1961 2. Existence of Reasonable Cause (Section 273B): That the Ld. CIT(A) failed to appreciate that the appellant had a "reasonable cause" for the delay in filing the audit report

Mahesh Prakash Bende, Mumbai vs. Income Tax Officer Circle 27(2), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 8028/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Mar 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmahesh Prakash Ito Circle - 27(2), Bende 4Th Floor, Tower No. 6, 302, 3Rd Floor, Prithvi Vs. It Office, Vashi Park, Sector-30, Vashi Railway Station Navi Mumbai-400 075 Building, Navi Mubmai – 400 703 Pan/Gir No. Alnpb2531M (Applicant) (Respondent) Assessee By Shri Devendra Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 25.02.2026 Date Of Pronouncement 20.03.2026

Section 142(1)Section 144Section 144BSection 147Section 148Section 151Section 249Section 249(3)Section 250

dismissing the appeal filed by appellant in limine on the ground of limitation - without condoning the delay in filing the appeal caused due to reasonable causes. 4. In the facts and circumstances of the case and in law, the Learned National Faceless Appeal Centre (NFAC), CIT(Appeals) has erred

Deepanshu Srivastava, Ghaziabad vs. DCIT, Circle 2(1)(1), Ghaziabad

ITA 4064/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 143(1)(a)Section 143(2)Section 143(3)Section 144B

erred in rejecting the books of accounts without duly appreciating that the Appellant was prevented by a just and reasonable cause from producing the same during the assessment proceedings and the CIT(A) has erred in upholding the same. 6. That on the facts and in the circumstances ... sector. The assessee purchases and sells scrap in the shape of plastic, iron, other metals and corrugated boxes. The assessee is prevented by a reasonable cause in furnishing these details as the books of accounts cannot be extracted. However the purchases and sales are supported by GSR returns which have

Deepanshu Srivastava, Ghaziabad vs. DCIT, Circle 2(1)(1), Ghaziabad

ITA 4063/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 143(1)(a)Section 143(2)Section 143(3)Section 144B

erred in rejecting the books of accounts without duly appreciating that the Appellant was prevented by a just and reasonable cause from producing the same during the assessment proceedings and the CIT(A) has erred in upholding the same. 6. That on the facts and in the circumstances ... sector. The assessee purchases and sells scrap in the shape of plastic, iron, other metals and corrugated boxes. The assessee is prevented by a reasonable cause in furnishing these details as the books of accounts cannot be extracted. However the purchases and sales are supported by GSR returns which have

Alaina Bullions Private Limited, New Delhi vs. DCIT Central Circle, Ghaziabad

In the result, appeals of the Revenue in ITA No

ITA 916/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] M/S Alaina Buillions Private Assistant Commissioner Of Limited, Income Tax, Central Circle, 1St Floor, Panna Bhawan, Nel Ghaziabad, Room No.229, 2Nd Vs Gali, Sarafa Bazar, Meerut, Floor, Cgo-1, Hapur Chungi, Uttar Pradesh-250002 Ghaziabad, Uttar Pradesh-201002 Pan-Aanca8659D Appellant Respondent

Section 153A

evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted the additional evidences without referring to any reasonable cause due to which the assessee was prevented to file these evidences before the Assessing Officer. Page 3 of 16 ITA Nos.1460, 1461 and 916/Del/2023 ... evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted the additional evidences without referring to any reasonable cause due to which the assessee was prevented to file these evidences before the Assessing Officer.” 10. As far as the additional grounds are concerned

ACIT, Central Circle, Ghaziabad vs. Alaina Bullions Private Limited, Meerut

In the result, appeals of the Revenue in ITA No

ITA 1461/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] M/S Alaina Buillions Private Assistant Commissioner Of Limited, Income Tax, Central Circle, 1St Floor, Panna Bhawan, Nel Ghaziabad, Room No.229, 2Nd Vs Gali, Sarafa Bazar, Meerut, Floor, Cgo-1, Hapur Chungi, Uttar Pradesh-250002 Ghaziabad, Uttar Pradesh-201002 Pan-Aanca8659D Appellant Respondent

Section 153A

evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted the additional evidences without referring to any reasonable cause due to which the assessee was prevented to file these evidences before the Assessing Officer. Page 3 of 16 ITA Nos.1460, 1461 and 916/Del/2023 ... evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted the additional evidences without referring to any reasonable cause due to which the assessee was prevented to file these evidences before the Assessing Officer.” 10. As far as the additional grounds are concerned

ACIT, Central Circle, Ghaziabad vs. Alaina Bullions Private Limited, Meerut

In the result, appeals of the Revenue in ITA No

ITA 1460/DEL/2023[2016-17]Status: DisposedITAT Delhi20 Mar 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] M/S Alaina Buillions Private Assistant Commissioner Of Limited, Income Tax, Central Circle, 1St Floor, Panna Bhawan, Nel Ghaziabad, Room No.229, 2Nd Vs Gali, Sarafa Bazar, Meerut, Floor, Cgo-1, Hapur Chungi, Uttar Pradesh-250002 Ghaziabad, Uttar Pradesh-201002 Pan-Aanca8659D Appellant Respondent

Section 153A

evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted the additional evidences without referring to any reasonable cause due to which the assessee was prevented to file these evidences before the Assessing Officer. Page 3 of 16 ITA Nos.1460, 1461 and 916/Del/2023 ... evidences could be filed before the Ld. CIT(A) was not satisfied, as the CIT(A) admitted the additional evidences without referring to any reasonable cause due to which the assessee was prevented to file these evidences before the Assessing Officer.” 10. As far as the additional grounds are concerned

Sneh Sanskar Gurukul Trust, New Delhi vs. Commissioner of Income Tax Exemption, New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 7451/DEL/2025[2022-23]Status: DisposedITAT Delhi18 Mar 2026AY 2022-23

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Naresh Sharma, CAFor Respondent: Shri Amit Jain, CIT(DR)
Section 12ASection 80G

circumstances of the case, we, hereby, condone the delay in filing of appeal by the assessee which is seen to be due to reasonable cause and entirely bonafide. 4. At the outset, Ld.AR has requested for an opportunity to demonstrate before the Ld. CIT(E) that the requisite conditions