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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

Manoj Singh, Howrah vs. ITO, Ward 40(1), Kolkata

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 832/KOL/2025[2022-2023]Status: DisposedITAT Kolkata23 Jul 2025AY 2022-2023

Bench: Shri George Mathanआयकर अपील सं/Ita Nos.829-832/Kol/2025 (नििाारण वर्ा / Assessment Year :2019-2020 To 2022-2023) Manoj Singh, Vs Ito, Ward-40 (1), Kolkata 406/1, G. T.Road (South) Howrah, West Bengal-711103 Pan No. : Alpps 5330 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Sunil Surana, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Addl.Jcit(A)-2, Jaipur, Dated 26.03.2025 For The Assessment Year 2019-2020, 2020-2021, 2021-2022 & 2022-2023, Respectively. 2. Shri Sunil Surana, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. During The Course Of Hearing, It Was Submitted By The Ld. Ar That The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Without Condoning The Delay. It Was The Submission That The Assessee Was Pursuing Alternative Remedy By Filing Rectification Application U/S.154 Of The Act Before The Ao & The Same Has Not Been Disposed Off By The Ld.Ao, Therefore, The Assessee Could Not File The Appeals Before The Ld. Cit(A) Within The Prescribed Time Limit. It Was The Submission That During The Pendency Of The Rectification Application The Assessee Opted To File Appeals Against The 2

For Respondent: Shri Shankar Naskar, Sr. DR
Section 143(1)Section 154

form of application u/s.154 of the Act and the same has not been disposed off by the Assessing Officer, which is a reasonable cause for delay in filing the appeals before the ld. CIT(A). Accordingly, the delay in filing the appeals before the ld.CIT(A) is condoned

Manoj Singh, Howrah vs. ITO, Ward 40(1), Kolkata

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 831/KOL/2025[2021-2022]Status: DisposedITAT Kolkata23 Jul 2025AY 2021-2022

Bench: Shri George Mathanआयकर अपील सं/Ita Nos.829-832/Kol/2025 (नििाारण वर्ा / Assessment Year :2019-2020 To 2022-2023) Manoj Singh, Vs Ito, Ward-40 (1), Kolkata 406/1, G. T.Road (South) Howrah, West Bengal-711103 Pan No. : Alpps 5330 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Sunil Surana, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Addl.Jcit(A)-2, Jaipur, Dated 26.03.2025 For The Assessment Year 2019-2020, 2020-2021, 2021-2022 & 2022-2023, Respectively. 2. Shri Sunil Surana, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. During The Course Of Hearing, It Was Submitted By The Ld. Ar That The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Without Condoning The Delay. It Was The Submission That The Assessee Was Pursuing Alternative Remedy By Filing Rectification Application U/S.154 Of The Act Before The Ao & The Same Has Not Been Disposed Off By The Ld.Ao, Therefore, The Assessee Could Not File The Appeals Before The Ld. Cit(A) Within The Prescribed Time Limit. It Was The Submission That During The Pendency Of The Rectification Application The Assessee Opted To File Appeals Against The 2

For Respondent: Shri Shankar Naskar, Sr. DR
Section 143(1)Section 154

form of application u/s.154 of the Act and the same has not been disposed off by the Assessing Officer, which is a reasonable cause for delay in filing the appeals before the ld. CIT(A). Accordingly, the delay in filing the appeals before the ld.CIT(A) is condoned

Manoj Singh, Howrah vs. ITO, Ward 40(1), Kolkata

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 830/KOL/2025[2020-2021]Status: DisposedITAT Kolkata23 Jul 2025AY 2020-2021

Bench: Shri George Mathanआयकर अपील सं/Ita Nos.829-832/Kol/2025 (नििाारण वर्ा / Assessment Year :2019-2020 To 2022-2023) Manoj Singh, Vs Ito, Ward-40 (1), Kolkata 406/1, G. T.Road (South) Howrah, West Bengal-711103 Pan No. : Alpps 5330 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Sunil Surana, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Addl.Jcit(A)-2, Jaipur, Dated 26.03.2025 For The Assessment Year 2019-2020, 2020-2021, 2021-2022 & 2022-2023, Respectively. 2. Shri Sunil Surana, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. During The Course Of Hearing, It Was Submitted By The Ld. Ar That The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Without Condoning The Delay. It Was The Submission That The Assessee Was Pursuing Alternative Remedy By Filing Rectification Application U/S.154 Of The Act Before The Ao & The Same Has Not Been Disposed Off By The Ld.Ao, Therefore, The Assessee Could Not File The Appeals Before The Ld. Cit(A) Within The Prescribed Time Limit. It Was The Submission That During The Pendency Of The Rectification Application The Assessee Opted To File Appeals Against The 2

For Respondent: Shri Shankar Naskar, Sr. DR
Section 143(1)Section 154

form of application u/s.154 of the Act and the same has not been disposed off by the Assessing Officer, which is a reasonable cause for delay in filing the appeals before the ld. CIT(A). Accordingly, the delay in filing the appeals before the ld.CIT(A) is condoned

Manoj Singh, Howrah vs. ITO, Ward 40(1), Kolkata

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 829/KOL/2025[2019-2020]Status: DisposedITAT Kolkata23 Jul 2025AY 2019-2020

Bench: Shri George Mathanआयकर अपील सं/Ita Nos.829-832/Kol/2025 (नििाारण वर्ा / Assessment Year :2019-2020 To 2022-2023) Manoj Singh, Vs Ito, Ward-40 (1), Kolkata 406/1, G. T.Road (South) Howrah, West Bengal-711103 Pan No. : Alpps 5330 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Sunil Surana, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Addl.Jcit(A)-2, Jaipur, Dated 26.03.2025 For The Assessment Year 2019-2020, 2020-2021, 2021-2022 & 2022-2023, Respectively. 2. Shri Sunil Surana, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. During The Course Of Hearing, It Was Submitted By The Ld. Ar That The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Without Condoning The Delay. It Was The Submission That The Assessee Was Pursuing Alternative Remedy By Filing Rectification Application U/S.154 Of The Act Before The Ao & The Same Has Not Been Disposed Off By The Ld.Ao, Therefore, The Assessee Could Not File The Appeals Before The Ld. Cit(A) Within The Prescribed Time Limit. It Was The Submission That During The Pendency Of The Rectification Application The Assessee Opted To File Appeals Against The 2

For Respondent: Shri Shankar Naskar, Sr. DR
Section 143(1)Section 154

form of application u/s.154 of the Act and the same has not been disposed off by the Assessing Officer, which is a reasonable cause for delay in filing the appeals before the ld. CIT(A). Accordingly, the delay in filing the appeals before the ld.CIT(A) is condoned

Electromechanical Trading Pvt. Ltd., Fortuna Tower vs. ITO 5(3), Aayakar Bhawan

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

ITA 1066/KOL/2025[2012-13]Status: DisposedITAT Kolkata23 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1066/Kol/2025 Assessment Year: 2012-13 Electromechanical Trading Pvt. Ltd. …………………....Appellant 23A, Ns Road, 11Th Floor, Room No.53, Kol-1. [Pan: Adcpa8526G] Vs. Ito, Ward-5(3), Kolkata……..……………..………………….…..... Respondent Appearances By: Shri Vijay Kr. Singhal, Fca Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 23, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 27.02.2024 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 358 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication. 3. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2012-13 By Declaring A Total Income Of Rs.50,050/- Which Was Processed Under Section 143(1) Of The Act. Subsequently, The Case Was Selected For Scrutiny & Notice Under

Section 131Section 143(1)Section 144Section 250Section 68

filed a condonation petition explaining the reasons or such delay. After considering the submissions and materials on record, we are satisfied that there was reasonable cause for the delay in filing the appeal. Accordingly, the said delay is condoned, and the appeal is admitted for adjudication. 3. Brief facts

Patteppadam Rural Cooperative Society Ltd, Thrissur vs. ITO, Ward-2, Thrissur

In the result, the appeal filed by the assessee stands allowed

ITA 392/COCH/2025[2020-21]Status: DisposedITAT Cochin22 Jul 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2020-21 Patteppadam Rural Cooperative Society Ltd. .......... Appellant Kottanellur P.O., Thrissur 680662 [Pan: Aaaap3007B] Vs. The Income Tax Officer, Ward 2(1), Thrissur .......... Respondent Appellant By: Shri C.A. Jojo, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 05.06.2025 Date Of Pronouncement: 22.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 17.12.2023 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That That Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. The Return Of Income For Ay 2020-21 Was Filed On 13.02.2021 Disclosing Total Income Of Rs. 85,810/- After Claiming

For Appellant: Shri C.A. Jojo, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(i)

condonation of delay, in the absence of any evidence contrary, we are of the considered opinion that the appellant society is prevented by sufficient reasonable cause in filing the appeal within the prescribed limit. Accordingly, we condone the delay and admit the appeal for adjudication. 6. We have heard