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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

Pawan Kumar, Ranchi vs. ITO, Ward-2(2), Ranchi

The appeal of the assessee is allowed for statistical purposes

ITA 487/RAN/2024[2016-17]Status: DisposedITAT Ranchi23 Jun 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.487/Ran/2024 Assessment Year: 2016-17 Pawan Kumar….………...................................…...........................……….……Appellant A/3, Manorama Enclave, Argora, Pundag Road, Ranchi, Jharkhand – 834012. [Pan: Agypk0863F] Vs. Ito, Ward-2(2), Ranchi……........…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 19, 2025 Date Of Pronouncing The Order : June 23, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 03.10.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 15 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & That The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. No One Has Appeared On Behalf Of The Assessee In Spite Of Serving Notices For Hearing & The Tribunal Cannot Keep This Appeal Pending For Indefinite Time Due To Non-Representation. Therefore, In The Absence Of Any Authorised Representative Of The Assessee, We Proceed To Decide The

Section 147Section 148Section 250Section 250(6)Section 68

filing the present appeal. The assessee filed an application for condonation of delay stating reasons for such delay. After considering the application, we find reasonable cause and that the delay was not intentional. We, therefore, condone the delay in filing the appeal and adjudicate the appeal on merits

Fule Ambedkar College of Social Work, Gadchiroli vs. ITO TDS 52(3), Chandrapur

In the result, appeal of the Assessee is allowed

ITA 226/NAG/2025[2013-14]Status: DisposedITAT Nagpur23 Jun 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy

For Appellant: Shri Mohd. Lakkadsha, Ld. CAFor Respondent: Shri Surjith Kumar Saha, Ld. Sr.DR
Section 234ESection 250

Scheme, 2024 for resolution of dispute and the same was rejected by the designated authority. The learned A.R. stated that there was sufficient and reasonable cause for this delay. 3. On the contrary, ld.DR refuted the claim of the assessee and submitted that concurrent findings of lower authorities need

Ambalapad Service Co Operative Bank Ltd No 759, Kundukad, Thrissur vs. Income Tax Officer, Thrissur

In the result, appeal filed by the assessee is allowed

ITA 78/COCH/2025[2012-2013]Status: DisposedITAT Cochin23 Jun 2025AY 2012-2013

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2012-13 Ambalapad Service Co-Op. Bank Ltd. .......... Appellant Xi/57, Kundukad P.O., Thrissur 680028 [Pan: Aadaa9298G] Vs. The Income Tax Officer, Ward 2(1), Thrissur .......... Respondent Appellant By: Shri Ramdas M., Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.05.2025 Date Of Pronouncement: 23.06.2025 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 03.12.2024 For Assessment Year (Ay) 2012-13. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As Primary Agricultural Co-Operative Society. The Appellant Had Not Filed Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). The Income

For Appellant: Shri Ramdas M., CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 143(3)Section 148Section 271BSection 44A

assessments, since delay in obtaining audit reports from statutory auditors under Kerala Co-operative Societies Act and Rules could be seen as a reasonable cause for delayed submission of audit reports, no penalty under section 271B was to be imposed on assessee.” 6. The facts of the case on hand

The Aroor Central Service Co-Operative Bank Limited, Alappuzha vs. ITO, Ward -2, Alappuzha

In the result, the appeals and stay applications filed by the assessee stand dismissed

ITA 372/COCH/2025[2021-22]Status: DisposedITAT Cochin23 Jun 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: Shri Suresh Kumar Varma, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 142(1)Section 143(1)Section 143(3)Section 250Section 80ASection 80P

till 13-05-2025). It is respectfully submitted that the above stated reasons may please be considered in the Petitioners' case for establishing reasonable cause, which prevented it from filing the appeal within the due date. Thus, the delay happened is due to reasons beyond the control of the petitioner

The Aroor Central Service Co-Operative Bank Limited, Alappuzha vs. ITO, Ward -5, Alappuzha

In the result, the appeals and stay applications filed by the assessee stand dismissed

ITA 371/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: Shri Suresh Kumar Varma, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 142(1)Section 143(1)Section 143(3)Section 250Section 80ASection 80P

till 13-05-2025). It is respectfully submitted that the above stated reasons may please be considered in the Petitioners' case for establishing reasonable cause, which prevented it from filing the appeal within the due date. Thus, the delay happened is due to reasons beyond the control of the petitioner

Harees Haneefa, Kollam vs. DCIT Circle Intl.Txn, Thiruvananthapuram

In the result, appeal filed by the assessee is dismissed as barred by limitation

ITA 286/COCH/2025[2016-17]Status: DisposedITAT Cochin23 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadavassessmentyear:2016-17

For Appellant: NoneFor Respondent: Smt. Leena Lal, Sr. D.R

delay of 452 days and the submissions made by the assessee in his condonation application are general in nature and hence, does not constitute reasonable cause. HareesHaneefa, Kollam Page 3 of 4 6. After considering the arguments of ld. D.R. and perusing the evidences for condonation of delay ... opinion that the explanation given by the assessee would not constitute reasonable cause. The explanation of the assessee is very general in nature without any supporting documents. It is settled position of law that now it is the cause behind the delay and not length of delay, which

Chandramoulieswara Charitable Trust, Trivandrum vs. CIT, Exemption, Trivandrum

In the result, appeals filed by the assessee are dismissed

ITA 276/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Smt. Divya Ravindran, A.RFor Respondent: Smt. Leena Lal, Sr. D.R

justice-oriented approach to condone thedelay”. In the present case the cause responsible for the delay would not fall under the ambit of “reasonable cause”. Therefore, we are not convinced with the reasons given by the assessee for condonation of appeal, and hence, the present appeal is dismissed as barred

Chandramoulieswara Charitable Trust, Trivandrum vs. CIT, Exemption, Trivandrum

In the result, appeals filed by the assessee are dismissed

ITA 275/COCH/2025[2016-17]Status: DisposedITAT Cochin23 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Smt. Divya Ravindran, A.RFor Respondent: Smt. Leena Lal, Sr. D.R

justice-oriented approach to condone thedelay”. In the present case the cause responsible for the delay would not fall under the ambit of “reasonable cause”. Therefore, we are not convinced with the reasons given by the assessee for condonation of appeal, and hence, the present appeal is dismissed as barred

Praveen Sidharthan Pillai, Kollam vs. The Income Tax Officer, Ward-3, Alappuzha

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

ITA 111/COCH/2025[2017-18]Status: DisposedITAT Cochin23 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadavassessmentyear:2017-18

For Appellant: Shri R. Krishnan, A.RFor Respondent: Smt. Leena Lal, Sr. D.R
Section 69

days in filing this appeal before us. Ld. Counsel for the assessee drawing attention of the bench pointed out that there was reasonable cause behind the non-filing of the appeal within time. 3. Ld. D.R. opposed the prayer of the counsel for the assessee. Praveen Sidharthan Pillai, Kollam Page

Peroorkada Service Co-Op Bank Ltd, Trivandrum vs. The ITO Ward-2(1), Trivandrum

In the result, the appeals filed by the assessee stand dismissed

ITA 387/COCH/2023[2018-19]Status: DisposedITAT Cochin23 Jun 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: ------- None -------For Respondent: Shri Sundarasan S., CIT-DR
Section 143(3)Section 68Section 80PSection 80P(2)(a)Section 80P(2)(i)

admitted for adjudication. On a perusal of the averments made in the condonation petition, it is evident that the appellant is prevented by reasonable cause from filing the appeal. Therefore, we condone the delay and admit the appeal for adjudication. 9. When the appeal was called on nobody appeared

Peroorkada Service Co-Op Bank Ltd, Trivandrum vs. The ITO Ward-2(1), Trivandrum

In the result, the appeals filed by the assessee stand dismissed

ITA 380/COCH/2023[2017-18]Status: DisposedITAT Cochin23 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: ------- None -------For Respondent: Shri Sundarasan S., CIT-DR
Section 143(3)Section 68Section 80PSection 80P(2)(a)Section 80P(2)(i)

admitted for adjudication. On a perusal of the averments made in the condonation petition, it is evident that the appellant is prevented by reasonable cause from filing the appeal. Therefore, we condone the delay and admit the appeal for adjudication. 9. When the appeal was called on nobody appeared

Peroorkada Service Co-Op Bank Ltd, Trivandrum vs. The ITO Ward-2(1), Trivandrum

In the result, the appeals filed by the assessee stand dismissed

ITA 343/COCH/2023[2016-17]Status: DisposedITAT Cochin23 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: ------- None -------For Respondent: Shri Sundarasan S., CIT-DR
Section 143(3)Section 68Section 80PSection 80P(2)(a)Section 80P(2)(i)

admitted for adjudication. On a perusal of the averments made in the condonation petition, it is evident that the appellant is prevented by reasonable cause from filing the appeal. Therefore, we condone the delay and admit the appeal for adjudication. 9. When the appeal was called on nobody appeared

Kamdhenu Foods, Sangli vs. ITO Ward 1 Sangli, Sangli

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

ITA 689/PUN/2025[2017-18]Status: DisposedITAT Pune23 Jun 2025AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.689/Pun/2025 Assessment Year : 2017-18

For Appellant: Smt. Deepa KhareFor Respondent: Date of hearing
Section 147Section 148Section 250

Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987) 2 SCC 107) I find that due to ‘reasonable cause’ assessee failed to file the appeal within the time limit stipulated under the Act. I therefore condone the delay of 286 days in filing the appeal ... 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

Kamdhenu Foods, Sangli vs. ITO Ward 1 Sangli, Sangli

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

ITA 688/PUN/2025[2016-17]Status: DisposedITAT Pune23 Jun 2025AY 2016-17

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.688/Pun/2025 Assessment Year : 2016-17 Kamdhenu Foods, Vs. Income Tax Officer, 177 Peth Nhag, Ward-1, Sangli Gavali Galli, Sangli – 416 416 Maharashtra Pan : Aaifk8508M Appellant Respondent

For Appellant: Smt. Deepa KhareFor Respondent: Date of hearing
Section 147Section 148Section 250Section 250(6)

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. 5. In the result

Shivraj Shankar Gundewadi, Miraj vs. NFAC, Delhi

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

ITA 525/PUN/2025[2017-18]Status: DisposedITAT Pune23 Jun 2025AY 2017-18

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.525/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Shivraj Shankar Gundewadi, Vs. Ito, Nfac, Delhi. At Post Salgare, Tal.- Miraj, Pin Code- 416418. Pan : Ajdpg2612C Appellant Respondent Assessee By : None Revenue By : Shri S. Sadananda Singh Date Of Hearing : 18.06.2025 Date Of Pronouncement : 23.06.2025 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 21.11.2023 Which Is Arising Out Of The Assessment Order U/S 147 R.W.S. 144 R.W.S.144B Of The Act For Assessment Year 2017-18 Framed On 30.03.2022 By The Ito, Nfac, Delhi. 2. When The Case Was Called For None Appeared On Behalf Of The Assessee. In The Past Also On The Dates Of Hearing Fixed On 02.04.2025 & 20.05.2025 Even After Validly Serving Of Notice Of Hearing, None Appeared Physically/Virtually. I Therefore Proceed To Deal With The Appeal.

For Appellant: NoneFor Respondent: Shri S. Sadananda Singh
Section 147Section 69

furnish latest e-mail ID and contact 4 details on the income tax portal and not to take adjournment unless otherwise required for reasonable cause. All the grounds of appeal raised by the assessee are allowed for statistical purposes. 6. In the result, the appeal of the assessee is allowed

Devdas Rajaram Shinde, Pune vs. ITO, Ward-9(4), Pune

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

ITA 277/PUN/2025[2012-13]Status: DisposedITAT Pune23 Jun 2025AY 2012-13

Bench: Dr.Manish Borad

For Appellant: Smt. Deepa KhareFor Respondent: Date of hearing
Section 143(3)Section 147Section 250Section 69A

Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987) 2 SCC 107) I find that due to ‘reasonable cause’ assessee failed to file the appeal within the time limit stipulated under the Act. I therefore condone the delay of 153 days in filing the appeal ... department for receiving the notices from ITBA portal. Assessee is further 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. Finding of ld.CIT(A) is set aside and effective grounds

Shree Vishweshwar Nagari Sahakari Path Sanstha, Pune vs. ITO, Pune

In the result, appeal of the assessee is allowed

ITA 1095/PUN/2025[2020-21]Status: DisposedITAT Pune23 Jun 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1095/Pun/2025 िनधा"रण वष" / Assessment Year: 2020-21 Shree Vishweshwar Nagari V The Income Tax Officer, Sahakari Path Sanstha, S 1St Floor, A Wing, New Sangvi Pune Pimpale Gurav, Pune - 411061, Maharashtra. Pan: Aadas2824C Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Sonal L Sonkavde – Addl.Cit(Dr) Date Of Hearing 04/06/2025 Date Of Pronouncement 23/06/2025

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

days in filing appeal before this Tribunal. We have perused the Affidavit filed by the assessee and are convinced that there is sufficient and reasonable cause for Delay. Accordingly, the Delay is condoned. 4.2 Admittedly, Assessee is a Co-operative Credit Society duly registered under Maharashtra Co-operative Societies

Ramchandra Dagdu Nikam, Satara vs. Income Tax Officer, Ward 3, Satara

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

ITA 2552/PUN/2024[2017-18]Status: DisposedITAT Pune23 Jun 2025AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sharad A ShahFor Respondent: Shri Vishal Makawane
Section 133(6)Section 143(2)Section 144Section 250

opportunities by the Ld. AO as well as Ld. CIT(A). However, he failed to make his submissions before them without there being any reasonable cause for such non-compliance. 7. We have heard the Ld. Representatives of the parties and perused the material available on records. The facts

Gayatri Eci, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

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

ITA 754/HYD/2024[2017-18]Status: DisposedITAT Hyderabad23 Jun 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 143(3)Section 144C

resulted in non-compliance before the Ld. CIT(A). In such circumstances, we are of the view that the assessee was prevented by a reasonable cause from prosecuting its appeal effectively. The Ld. DR objected to the remand by contending that adequate opportunities were already provided

Srinivas Emmadi, Hyderabad vs. Income Tax Officer, Ward-1, Sangareddy

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

ITA 32/HYD/2024[2014-15]Status: DisposedITAT Hyderabad23 Jun 2025AY 2014-15

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.32/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2014-15) Shri Srinivas Emmadi, Hyderabad. Pan:Aafpe1439A (Appellant) Vs. Income Tax Officer, Ward 1, Sangareddy. (Respondent) निर्धारिती द्वारा/Assessee By: Shri S. Rama Rao, Advocate राजस्व द्वारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 11/06/2025 घोषणा की रीख/Pronounce Ment: 23/06/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Shri Srinivas Emmadi ("The Assessee"), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)"), Dated 20.06.2023 For The A.Y. 2014-15.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 143(2)Section 144

bench to condone the delay in filing of the appeal. 3.2 After hearing the Learned Department Representative ("Ld. DR"), we found that there was reasonable cause for the delay in filing of the appeal. Accordingly, we condone the delay in filing of the appeal and admit the appeal for adjudication