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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

Income Tax Officer, Wanaparthy Block vs. Tamilnadu Special Police Employees Cooperative, Tsp Camp

In the result the appeal of the revenue is dismissed

ITA 363/CHNY/2025[2020-21]Status: DisposedITAT Chennai15 Jul 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:363/Chny/2025 िनधा"रण वष" / Assessment Year: 2020-21 Income Tax Officer, Tamilnadu Special Police Non-Corporate Ward -7(3), Vs. Employees Cooperative, Chennai – 600 034. Avadi, Chennai – 600 054. [Pan:Aafat-0366-E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Sita Krishnamoorthy, J.C.I.T. ""थ" की ओर से/Respondent By : Shri. G. Reddi Prakash, C.A. सुनवाई की तारीख/Date Of Hearing : 12.06.2025 घोषणा की तारीख/Date Of Pronouncement : 15.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: This Appeal By The Revenue Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2020-21, Dated 11.10.2024. 2. At The Outset, We Find That There Is A Delay Of 34 Days In Appeal Filed By The Revenue, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition Filed By The Revenue & Also Hearing Both The Parties, We Find That There Is A Reasonable Cause For The Revenue In Not Filing Appeal On Or Before The Due Date Prescribed Under The Law & Thus

For Appellant: Ms. Sita Krishnamoorthy, J.C.I.TFor Respondent: Shri. G. Reddi Prakash, C.A
Section 80PSection 80P(1)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

delay has been filed. After considering the petition filed by the revenue and also hearing both the parties, we find that there is a reasonable cause for the revenue in not filing appeal on or before the due date prescribed under the law and thus, :-2-: ITA. No:363/Chny/2025

Alfha Coach Builders, Karur vs. ITO, Ward-1, Karur

In the result, all six these appeals filed by the assessee are allowed

ITA 33/CHNY/2025[2015-16]Status: DisposedITAT Chennai15 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 32 & 33/Chny/2025 िनधा"रण वष" / Assessment Years: 2014-15 & 2015-16 Alfha Coach Builders, The Income Tax Officer, Sf No.596’3, Andan Kovil East, Vs. Ward -1, Pudhur, Covai Road, Karur. Karur – 639 002. [Pan: Aaofa-8970-D] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri J. Saravanan, AdvocateFor Respondent: Shri P. Krishna Kumar, JCIT
Section 154Section 200ASection 234ESection 250

appeals by the assessee. After considering the Affidavits filed by the assessee and also hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeals on or before the due date prescribed under the law and thus, in the interests of justice

Alfha Coach Builders, Karur vs. ITO, Ward-1, Karur

In the result, all six these appeals filed by the assessee are allowed

ITA 32/CHNY/2025[2014-15]Status: DisposedITAT Chennai15 Jul 2025AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 32 & 33/Chny/2025 िनधा"रण वष" / Assessment Years: 2014-15 & 2015-16 Alfha Coach Builders, The Income Tax Officer, Sf No.596’3, Andan Kovil East, Vs. Ward -1, Pudhur, Covai Road, Karur. Karur – 639 002. [Pan: Aaofa-8970-D] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri J. Saravanan, AdvocateFor Respondent: Shri P. Krishna Kumar, JCIT
Section 154Section 200ASection 234ESection 250

appeals by the assessee. After considering the Affidavits filed by the assessee and also hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeals on or before the due date prescribed under the law and thus, in the interests of justice

Prem Educational Trust, Vellore vs. ITO Exemption Ward-1, Chennai

In the result, appeal filed by the assessee is allowed for statistical

ITA 16/CHNY/2025[-]Status: DisposedITAT Chennai15 Jul 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Abhishek Murali, CAFor Respondent: Mr.Bipin C.N., CIT
Section 11Section 12Section 12ASection 12A(1)(ac)

cause of delay. Having gone through the contents of the application and the affidavit filed by the assessee, we find that there is reasonable cause for delay which we excuse and proceed to adjudicate the appeal on its merits. 3. The brief facts brought to our notice by the Ld.AR

Institute Voluntas Dei, Madurai vs. CIT, Exemptions, Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1002/CHNY/2025[-]Status: DisposedITAT Chennai15 Jul 2025

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1002/Chny/2025 Institute Voluntas Dei, Cit (Exemptions), 2/462, Ivd Seminary, Lkb Nagar, Vs. Chennai. Sakkimangalam, Elamanur Post, Madurai – 625 201. [Pan:Aabai-5537-J] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. T. Vasudevan, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 12ASection 12A(1)(ac)

appeal by the assessee. After considering the Affidavit filed by the assessee and also hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice

Jurimatrix Services India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle 4(3)(1), Bengaluru

ITA 92/BANG/2025[2018-19]Status: DisposedITAT Bangalore15 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri K.R. Girish, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 10ASection 115JSection 144Section 156Section 234ASection 234BSection 263Section 270A

ITA No.92/Bang/2025 Jurimatrix Services India Private Limited, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL "A"BENCH: BANGALORE BEFORE SHRI WASEEM

M/S Hussain Multispeciality Hospital, Bijapur vs. The Income Tax Officer, Ward-1, Vijayapur

In the result, appeal of the assessee is partly allowed for

ITA 2387/BANG/2024[2016-17]Status: DisposedITAT Bangalore15 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 250Section 40

days in filing the said appeal. 4. It is most respectfully submitted that in view of the aforementioned reasons, the Applicant was prevented by reasonable cause and there was absolutely no negligence on his part in prosecuting and filing of an appeal. The Applicant took all due diligence to file ... assessee for not presenting the appeals within the prescribed time. The explanation therefore, becomes relevant to determine whether the same reflect sufficient and reasonable cause on the part of the assessee in not filing these appeals within the prescribed time. 6.1 While considering a similar issue the Apex Court

Damjibhai Lekhrajbhai Thavrani, Junagadh vs. Income Tax Officer, Ward-1, Junagadh

Appeal is allowed for statistical purpose

ITA 58/RJT/2025[2008-09]Status: DisposedITAT Rajkot14 Jul 2025AY 2008-09

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.58/Rjt/2025 "नधा"रणवष" / Assessment Year: (2008-09) (Hybrid Hearing) Damjibhai Lekharjibhai Thavrani Vs. Income-Tax Officer, C/O. Sarda & Sarda (Ca), Sakar 1St Ito Ward – 1 Floor, Dr. Radha-Krishnan Road, Income Tax Office, Bhootnath Opp. Rajkumar College, Chamber, Rajkot - 360001 Junagadh - 362001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aeypt7701B (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit. Dr Date Of Hearing : 07/ 05 /2025 Date Of Pronouncement : 14/ 07/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT. DR
Section 144Section 249(2)Section 249(3)

following observation: “For these reasons, the delay of 1542 days in filing of appeal in this case is not condoned as no "sufficient and reasonable cause" has been shown u/s.249(3) of the Income Tax Act, 1961 for the appellant's failure to file the appeal within the prescribed period

Chandrakant Pandurang Kharat, Panvel vs. Commissioner of Income-Tax (Appeals), New Delhi

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

ITA 1535/PUN/2025[2018-2019]Status: DisposedITAT Pune14 Jul 2025AY 2018-2019

Bench: Dr.Manish Borad

For Appellant: Smt Pramod S ShingteFor Respondent: Shri Deepak Kumar Kedia
Section 147Section 148Section 250Section 250(6)

email id and contact detail on ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order 3 Chandrakant Pandurang Kharat is set aside and the effective ground of appeal raised by the assessee is allowed for statistical purposes

Ram Sopan Jadhav, Solapur vs. ITO, Ward-1(1), Solapur

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

ITA 1491/PUN/2025[2015-16]Status: DisposedITAT Pune14 Jul 2025AY 2015-16

Bench: Dr.Manish Borad

For Appellant: Smt Deepa KhareFor Respondent: Shri Deepak Kumar Kedia
Section 10(1)Section 142(1)Section 147Section 148Section 250Section 271Section 69A

merits.” 4 Ram Sopan Jadhav 6. On going through the averments made by the assessee, I am of the view that due to ‘reasonable cause’ assessee failed to file the appeal within the stipulated time. 7. The appellate remedy or forum is created by the statute is to rest ... email id and contact detail on ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 9. In the result

SHI vs. Ahyadri Bahuuddeshiya Sevabhavi Sanstha, Sangamner, Ahmed Nagarvs.Exemption Ward 1(1), Nsk, Nashik

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

ITA 1461/PUN/2025[2025-26]Status: DisposedITAT Pune14 Jul 2025AY 2025-26

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1461/Pun/2025 धििाारण वर्ा / Assessment Year: 2025-2026 Vs Exemption Ward 1(1), Shivsahyadri Bahuuddeshiya Sevabhavi Nashik Sanstha, 1, Nimgaon Paga Tal Sangamner, Ahmednagar, Ahmednagar-422002 Maharashtra Pan-Aasts5988D Appellant Respondent

For Appellant: Shri Rajendra NivruttiFor Respondent: Shri Amit Bobde-CIT
Section 12ASection 80GSection 80G(5)

dated 10.03.2025. 2. There is a delay of 26 days in filing of this appeal. Application for condonation of delay stands filed. Considering the reasonable cause, delay is condoned and appeal is admitted for adjudication. 2 3. Assessee has raised following grounds of appeal 1. On the facts

Gangagiri Maharaj Betsarala Mahila Nagari Patsanstha Ltd, Nashik vs. ITO Ward 1(1), Nashik

In the result, appeal of the assessee is partly allowed

ITA 1418/PUN/2025[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Dr.Manish Borad

For Appellant: Shri Sanket JoshiFor Respondent: Date of hearing
Section 144Section 250Section 5Section 69ASection 80PSection 80P(2)(a)

filing the present appeal before Hon'ble ITAT. The assessee submits that the above delay in filing the appeal was on account of reasonable cause. 2. In this regard, it is submitted that the appellant is a small credit cooperative society based in Nashik. Upon receipt of the appellate order ... ratio laid down by the Hon’ble Court in the case of Inder Singh (supra), I am of the view that due to ‘reasonable cause’ assessee failed to file the appeal within the stipulated time. I therefore condone the delay of 455 days and admit the appeal for adjudication

Mohan Haribhau Khedkar, Pune vs. I.T.O Ward-4(4), Pune

In the result, appeal of the assessee is partly allowed

ITA 1299/PUN/2025[2014-15]Status: DisposedITAT Pune14 Jul 2025AY 2014-15

Bench: Dr.Manish Borad

For Appellant: Shri Rohit S. TapadiyaFor Respondent: Shri Deepak Kumar Kedia
Section 143(3)Section 147Section 148Section 250Section 5

ratio laid down by the Hon’ble Court in the case of Inder Singh (supra), I am of the view that due to ‘reasonable cause’ assessee failed to file appeal within the stipulated time. I therefore condone the delay of 20 days and admit the appeal for adjudication. 6. During

Maheshkumar Uttamchand Mutha, Dhule vs. ITO Ward 1, Dhule

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

ITA 10/PUN/2025[2013-14]Status: DisposedITAT Pune14 Jul 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Respondent: Appellant by Shri Sanket M Joshi
Section 147Section 250

notices from ITBA portal. Assessee is also directed to remain vigilant and not to 3 Maheshkumar Uttamchand Mutha take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 5. In the result

Mohan Tryambak Pawar, Nashik vs. ACIT, Circle 1, Nashik

In the result, the appeal filed by the assessee is allowed for

ITA 2521/PUN/2024[2011-12]Status: DisposedITAT Pune14 Jul 2025AY 2011-12

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2521/Pun/2024 "नधा"रण वष" / Assessment Year : 2011-12

For Appellant: Shri Sanket M. Joshi
Section 143(3)Section 250Section 250(6)Section 271(1)(c)

days. Ld. CIT(A)/NFAC did not condone the delay. 5. We however considering the facts of the case and that of the reasonable cause prevented the assessee from filing the appeal and also taking the consideration laid down by the judgement of Hon’ble Supreme Court in the case

Ma Chimanraoji Kadam Gr Bigar Seti Sah Path Mar Saswad, Satara vs. ITO, Ward-3, Satara

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

ITA 2494/PUN/2024[2020-21]Status: DisposedITAT Pune14 Jul 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar CIT-DR
Section 144Section 250Section 68Section 80PSection 80P(2)(d)

department for receiving the notices from ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 7. In the result

M/S Jyoti Solutionworks Pvt. Ltd, Pune vs. DCIT, Circle 8, Pune

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

ITA 2317/PUN/2024[2009-10]Status: DisposedITAT Pune14 Jul 2025AY 2009-10

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2317/Pun/2024 Assessment Year : 2009-10

For Appellant: Shri Kishor B PhadkeFor Respondent: Date of hearing
Section 143(3)Section 250Section 5

ratio laid down by the Hon’ble Court in the case of Inder Singh (supra), we are of the view that due to ‘reasonable cause’ assessee failed to file the appeal within the stipulated time. We therefore condone the delay of 480 days and admit the appeal for adjudication ... Rectification Application against order u/s.250 and other documents for Amalgamation of the appellant with Jyoti Stampings and Assemblies Private Limited. 8. Considering the ‘reasonable cause’ and that the assessee was not able to get the information about the notices of hearing resulting into exparte order by ld.CIT

Ashok Damodhar Gholap, Nashik vs. ITO Ward 1(1), Nashik

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

ITA 2074/PUN/2024[2015-16]Status: DisposedITAT Pune14 Jul 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Deepa KhareFor Respondent: Shri Ramnath P Murkunde
Section 147Section 148Section 250Section 250(6)

dates of hearing appeal of the assessee has been dismissed by Ld. CIT(A) in limine as time barred by limitation. She stated that ‘reasonable cause’ prevented the assessee from filing the appeal. She therefore prayed that the appeal may be condoned and the matter may be restored ... email id and contact detail on ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 5. In the result

Mohsin Ahmad Abdul Lateef, Nashik vs. ITO, Ward-1, Malegaon

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

ITA 1926/PUN/2024[2019-20]Status: DisposedITAT Pune14 Jul 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1926/Pun/2024 Assessment Year : 2019-20 Moshin Ahmad Abdul Lateef, Vs. Income Tax Officer, Anmol Fabtex, Sr.No.15, Ward-1, Malegaon Near Fire Station, Durga Wadi, Malegaon, Malegaon City, S.O., Nashik – 423 203 Maharashtra Pan : Anfpa2272G Appellant Respondent

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ramnath P. Murkunde
Section 142(1)Section 147Section 250Section 250(6)Section 271ASection 44A

contact detail on the ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 6. In the result, appeal

Jagdamba Gramin Bigarsheti Sahakari Patsanstha Maryadit, Ahmednagar vs. ITO Ward-2, Ahmednagar

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

ITA 1686/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Prasad R KulkarniFor Respondent: Shri Ramnath P Murkunde
Section 144Section 147Section 148Section 250

department for receiving the notices from ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. 3 Jagdamba Gramin Bigarsheti Sahakari Patsanstha Maryadit Impugned order is set aside. The effective grounds raised by the assessee are allowed for statistical purposes