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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

Sri Kannika Esakkiammal Charitable Trust, Madurai vs. CIT Exemtpions, Chennai

In the result, all the six appeals filed by the assessees are allowed for statistical purposes

ITA 732/CHNY/2025[-]Status: DisposedITAT Chennai11 Jun 2025

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 & 728/Chny/2025 Slp Govindarajan Vijayalakshmi Cit (Exemptions), Educational Charitable Trust, Vs. Chennai. Plot No.2 Lovely Home, Bharathiyar Nagar, 3Rd Street Alagappan Nagar Extension, Madurai – 625 003. [Pan:Abgts-1299-A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./Ita Nos.:729 & 730/Chny/2025 M. Sundaram Educational Charitable Cit (Exemptions), Trust, Vs. Chennai. No -2B Kamala 2Nd Street, Chinna Chokkikulam, Sokkikulam S.O., Madurai – 625 002. [Pan:Aaitm-5247-K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./Ita Nos.:731 & 732/Chny/2025 Sri Kannika Esakkiammal Charitable Cit (Exemptions), Trust, Vs. Chennai. Tpk Road Andalpuram, Madurai – 625 003. [Pan:Abets-7218-K] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. M.K.Biju, CIT–DR. by Virtual
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

days in appeal filed by the assessee in ITA Nos.727, 729 & 731/Chny/2025. After hearing from 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

Sri Kannika Esakkiammal Charitable Trust, Madurai vs. CIT Exemptions, Chennai

In the result, all the six appeals filed by the assessees are allowed for statistical purposes

ITA 731/CHNY/2025[-]Status: DisposedITAT Chennai11 Jun 2025

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 & 728/Chny/2025 Slp Govindarajan Vijayalakshmi Cit (Exemptions), Educational Charitable Trust, Vs. Chennai. Plot No.2 Lovely Home, Bharathiyar Nagar, 3Rd Street Alagappan Nagar Extension, Madurai – 625 003. [Pan:Abgts-1299-A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./Ita Nos.:729 & 730/Chny/2025 M. Sundaram Educational Charitable Cit (Exemptions), Trust, Vs. Chennai. No -2B Kamala 2Nd Street, Chinna Chokkikulam, Sokkikulam S.O., Madurai – 625 002. [Pan:Aaitm-5247-K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./Ita Nos.:731 & 732/Chny/2025 Sri Kannika Esakkiammal Charitable Cit (Exemptions), Trust, Vs. Chennai. Tpk Road Andalpuram, Madurai – 625 003. [Pan:Abets-7218-K] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. M.K.Biju, CIT–DR. by Virtual
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

days in appeal filed by the assessee in ITA Nos.727, 729 & 731/Chny/2025. After hearing from 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

M Sundaram Educational Charitable Trust, Madurai vs. CIT Exemptions, Chennai

In the result, all the six appeals filed by the assessees are allowed for statistical purposes

ITA 730/CHNY/2025[-]Status: DisposedITAT Chennai11 Jun 2025

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 & 728/Chny/2025 Slp Govindarajan Vijayalakshmi Cit (Exemptions), Educational Charitable Trust, Vs. Chennai. Plot No.2 Lovely Home, Bharathiyar Nagar, 3Rd Street Alagappan Nagar Extension, Madurai – 625 003. [Pan:Abgts-1299-A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./Ita Nos.:729 & 730/Chny/2025 M. Sundaram Educational Charitable Cit (Exemptions), Trust, Vs. Chennai. No -2B Kamala 2Nd Street, Chinna Chokkikulam, Sokkikulam S.O., Madurai – 625 002. [Pan:Aaitm-5247-K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./Ita Nos.:731 & 732/Chny/2025 Sri Kannika Esakkiammal Charitable Cit (Exemptions), Trust, Vs. Chennai. Tpk Road Andalpuram, Madurai – 625 003. [Pan:Abets-7218-K] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. M.K.Biju, CIT–DR. by Virtual
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

days in appeal filed by the assessee in ITA Nos.727, 729 & 731/Chny/2025. After hearing from 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

Sanvedna Educational and Charitable Turst, Mumbai vs. ITO, Exemption Ward, Thane

In the result the appeal filed by the Assessee stands dismissed as withdrawn with liberty as granted above

ITA 2609/MUM/2025[2021-22]Status: DisposedITAT Mumbai11 Jun 2025AY 2021-22

Bench: Shri Narender Kumar Choudhryassessment Year: 2021-22 Sanvedna Educational & Ito, Exemption Ward, Charitable Trust Thane Room No.208,2Nd Floor, C/O Chandu Hansha Dalvi, Vs. House No. 52, Anand Koliwada, Reac, Thane Dativali Village, Diva(East), Mumbai-400602 District Thane, Mumbai- 400612 Pan: Aagts4216G (Appellant) (Respondent) Present For: Assessee By : Shri Prayag Jha Revenue By : Shri Kavan Limbasiya, Ld. Sr.D.R. Date Of Hearing : 11.06.2025 Date Of Pronouncement : 11.06.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 14.02.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2. On Deliberation, The Assessee Has Claimed That There Was A Delay In Filing Of Form No. 10 For Claiming Benefit U/S 11 Of The Act & Therefore The Benefit U/S 11 Of The Act Has Been Denied By Both The Authorities Below.

For Appellant: Shri Prayag JhaFor Respondent: Shri Kavan Limbasiya, Ld. Sr.D.R
Section 11Section 115BSection 139(1)Section 250

Filing Status” in “Part A-GEN” of the Form of Return of Income ITR-6; and The assessee was prevented by reasonable cause from filing such Form before the expiry of the time allowed, and the case is of genuine hardship on merits. 4. The Assessee’s case falls within

Neha Singh, New Delhi vs. Assessing Officer, Civic Centre, New Delhi

Appeal is partly allowed in the aforesaid terms

ITA 874/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Jun 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Neha Singh, Vs. Income Tax Officer, D-119, 3Rd Floor, Sarita Vihar, Ward 72(1), Delhi New Delhi – 110 076 (Pan: Cksps4013F) (Appellant) (Respondent) Appellant By : Shri Sudarshan Roy, Adv. & Shri Ujjawal Garg, Ar Respondent By : Shri Shyam Manohar Singh, Sr. Dr. Date Of Hearing 08.05.2025 Date Of Pronouncement 11.06.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Nfac, Delhi In Appeal No. Itba/Nfac/S/250/2024-25/1069313809(1) Dated 01.10.2024 Relating To Assessment Year 2017-18. 2. Heard Both The Sides & Perused The Records. 3. At The Threshold, It Is Noted That There Is A Delay Of 48 Days In Filing The Appeal Before The Tribunal & During The Hearing, It Is Observed That Reasonable Cause Has Been Attributed To The Assessee For Filing The Belated Appeal. Hence, I Condone The Delay In Dispute & Proceed Further. 4. Brief Facts Of The Case Are That Ao Made The Addition Of Rs.28,80,000/- By Noting That Assessee Deposited Cash In Bank Account During Demonetization Period From Undisclosed Sources, As The Sources Were Neither Properly Explained, The Onus Is On The Assessee’S To Prove That The Cash Deposits, Hence, Ao Added The Same To The Income Of The Assessee As Income From Undisclosed Sources & The Same Was Taxed U/S. 115Bbe @ 60%. However, In Appeal, Ld. First Appellate Authority Sustained The Addition. Against The Above, Assessee Appealed Before The Tribunal.

For Appellant: Shri Sudarshan Roy, Adv. &For Respondent: Shri Shyam Manohar Singh, Sr. DR
Section 115B

noted that there is a delay of 48 days in filing the appeal before the Tribunal and during the hearing, it is observed that reasonable cause has been attributed to the assessee for filing the belated appeal. Hence, I condone the delay in dispute and proceed further. 4. Brief facts

Braham Singh, New Delhi vs. Assessment Unit, Income Tax Department, Central Delhi

Appeal is allowed for statistical purposes

ITA 5731/DEL/2024[2016-17]Status: DisposedITAT Delhi11 Jun 2025AY 2016-17

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2016-17 Braham Singh, Vs. Assessment Unit, Village Hasanpur Po Ujwa Income Tax Deptt. Chander, New Delhi – 110 073 Room No. 402, Mayur Bhawan, Connaght Place, New Delhi – 1 (Pan: Fhmps9910M) (Appellant) (Respondent) Appellant By : Sh. Vivek Bansal, Adv. Respondent By : Sh. Shyam Manohar Singh, Sr. Dr. Date Of Hearing 08.05.2025 Date Of Pronouncement 11.06.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Nfac, Delhi In Appeal No. Itba/Nfac/S/250/2024-25/1068073346(1) Dated 28.8.2024 Relating To Assessment Year 2016-17. 2. Heard Both The Parties At Length & Perused The Records. 3. It Transpires That There Is Delay Of 41 Days In Filing The Appeal Before The Tribunal. During The Hearing, Reasonable Cause Has Been Attributed To The Assessee For Filing The Belated Appeal Before The Tribunal. Hence, I Am Condoning The Delay In Dispute In Filing The Appeal Before The Tribunal. 4. It Also Emerges With The Able Assistance Coming From Both The Sides That The Learned Cit(A)/Nfac Has Refused To Condone The Corresponding Delay Of 162 Days In Institution Of The Assessee’S Lower

For Appellant: Sh. Vivek Bansal, AdvFor Respondent: Sh. Shyam Manohar Singh, Sr. DR
Section 271(1)(c)

perused the records. 3. It transpires that there is delay of 41 days in filing the appeal before the Tribunal. During the hearing, reasonable cause has been attributed to the assessee for filing the belated appeal before the Tribunal. Hence, I am condoning the delay in dispute in filing

Zuari Industries Limited (Formerly Known As Zuari Global Ltd), Zuarinagar vs. Deputy Commissioner of Income Tax, Circle - 1(1), Panaji

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

ITA 71/PAN/2025[2018-19]Status: DisposedITAT Panaji10 Jun 2025AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.71/Pan/2025 (A.Y. 2018-19 ) Zuari Industries Limited, Vs National Faceless Jai Kisaan Bhawan, Assessment Centre, Zuarinagar, Delhi. Mormugo, Goa-403728. Pan/Gir No. Aaacz0306P (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri.Ankit Goyal.Ar Revenue By Shri.Captain Pradeep Arya.Dr सुनवाई क" तार"ख/Date Of Hearing 10.06.2025 घोषणा क" तार"ख/Date Of Pronouncement 11.06.2025 Order Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assesse Against The Order Of National Faceless Appeal Centre (Nfac) Delhi /Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assesse Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Disallowance U/Sec14Aof The Act & Not Condoning The Delay In Filling The Appeal. 2. The Brief Facts Of The Case Are That, The Assesse Company Is Engaged In The Business. The Assesse Has Filed The Return Of Income For A.Y.2018-19 On 29.11.2018 Disclosing

Section 14A

passed the order considering the fact that there is no proper compliance and the delay in filling the appeal was not explained with the reasonable cause. Whereas the assessee has raised grounds of appeal challenging the disallowance u/sec14A of the Act by the A.O and the Ld.AR demonstrated the intimation ... Considering the facts,provisions, find that the submissions of the Ld.AR are realistic and the limitation period is applicable in Covid2019 pandemic and the reasonable cause is explained. We find that no benefit is derived in causing delay in filing appeal before the CIT(A) and also the assessee