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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

Kowlanahalli Ningegowda Somashekar, Bangalore vs. Income Tax Officer, Ward-5(2)(3), Bangalore

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

ITA 1045/BANG/2025[2021-13]Status: DisposedITAT Bangalore12 Feb 2026AY 2021-13

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2012-13

For Appellant: Ms. Pooja Maru, A.RFor Respondent: Sri Balusamy N., D.R
Section 250Section 253(5)

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. We have gone through the reasons explained by the assessee ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for not filing the appeal. We have to see the cause for the delay. When there was a reasonable cause, the period of delay

Jatin Dhansukh Khatri, Mumbai vs. ITO Ward 42(2)(3), Mumbai

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

ITA 8978/MUM/2025[2013-14]Status: DisposedITAT Mumbai12 Feb 2026AY 2013-14

Bench: Shri Pawan Singh & Shri Bijayananda Prusethjatin Dhansukh Khatri, Vs. Ito Ward-42(2)(3), J/204 Raj Gulmohar Bldg Kautilya Bhavan, No.1 Near St. Xavier Mumbai-400051. School Unitech Westend Virar (West) Thane-401303. Pan/Gir No: Ahgpk2461A (Appellant) (Respondent)

Section 144Section 147Section 148Section 249(3)Section 250Section 264

assessee are as under: “The CIT Appeal had not given proper opportunity of being heard to represent the case even though there was a reasonable cause for filing the appeal and confirming the addition of Rs. 10,57,890/-. 2) The Ld. CIT Appeal has not decided the appeal

Amarchand Lakhmichand Narang, Mumbai vs. ITO Ward 12(1)(2), Mumbai

In the result, grounds of appeal raised by assessee are allowed for statistical

ITA 8977/MUM/2025[2016-17]Status: HeardITAT Mumbai12 Feb 2026AY 2016-17

Bench: Shri Pawan Singh& Shri Bijayananda Pruseth(Physical Hearing)

Section 254(1)

Amarchand Lakhmichand Narang step to file appeal. The assessee engaged other consultant and file appeal before ld CIT(A). There was reasonable cause to condone such delay. The assessee is interested to persue his case on merit. The appeal of assessee was dismissed in limine, without considering the merits

Kishor Changya Patil, Mumbai vs. ITO-41(1)(2), Mumbai

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

ITA 7936/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 144Section 147

fide explanation furnished by the assessee supported by affidavit and surrounding factual circumstances, we are satisfied that the assessee was prevented by sufficient and reasonable cause from filing the appeals before the learned CIT(A) within the prescribed period of limitation. Accordingly, the delay in filing the appeals before

Kishor Changya Patil, Mumbai vs. ITO-41(1)(2), Mumbai

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

ITA 7935/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 144Section 147

fide explanation furnished by the assessee supported by affidavit and surrounding factual circumstances, we are satisfied that the assessee was prevented by sufficient and reasonable cause from filing the appeals before the learned CIT(A) within the prescribed period of limitation. Accordingly, the delay in filing the appeals before

Kishor Changya Patil, Mumbai vs. ITO41(1)(2), Mumbai

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

ITA 7934/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 144Section 147

fide explanation furnished by the assessee supported by affidavit and surrounding factual circumstances, we are satisfied that the assessee was prevented by sufficient and reasonable cause from filing the appeals before the learned CIT(A) within the prescribed period of limitation. Accordingly, the delay in filing the appeals before

Income Tax Officer, Ward-49(1), Delhi vs. Hema Arora, Delhi

In the result, appeal filed by the revenue is dismissed

ITA 6324/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Feb 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 133(6)Section 143(2)Section 44ASection 69A

have heard Ld. DR on the issue of condonation of delay. In our considered opinion, there was a reasonable cause for the delay in filing the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal. 5. Brief facts of the case are, assessee is an individual

Mr. Rakesh, Haryana vs. ITO, Ward-18(3), Delhi

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

ITA 5499/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Feb 2026AY 2017-18

Bench: Shri.Rifaur Rahman & Shri Vimal Kumarmr. Rakesh, 59/20, Rameshwar Puram, Gali No.1, Kabirpur, Sonipat, Haryana 131001 Pan: Brwpr6769P ...... Appellant Vs. Ito, Ward-18(3), Cr Building, I.P Estate, New Delhi 110002 ..... Respondent

For Appellant: Ms. Shilpi Jain, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 44ASection 68

submissions, we found that the delay deserves to be condoned, as 2 the assessee was prevented from filing the appeal on time for reasonable cause. Accordingly, the delay is condoned and the appeal is admitted. 3. It was further brought to our notice that the case of the assessee

Zeta Buildtech Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Central Circle-7, Delhi

In the result, appeal filed by the assessee is allowed

ITA 3449/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

For Appellant: Sh. Suresh Kumar Gupta, CAFor Respondent: Ms. Ankush Kalra, Sr.DR
Section 142(1)Section 143(1)(a)Section 143(2)

days. 3. We have heard both the counsels on the issue of condonation of delay. In our considered opinion, there was a reasonable cause for the delay in 2 filing the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal. 4. Brief facts of the case

Satish Kumar Arora, Agra vs. Income Tax Officer 1(1)(2), Agra

In the result, the appeal of the assessee is dismissed

ITA 510/AGR/2025[2014-15]Status: DisposedITAT Agra11 Feb 2026AY 2014-15

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singhsatish Kumar Arora, Vs. Income Tax Officer, 1 Ashok Enclave Dayal Watd-1(1)(2), Bagh, Agra, Up Agra, Up (Appellant) (Respondent) Pan: Aampa0703C Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 11/02/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 144Section 153ASection 271A

provisions of section 271AAB of the Act does not grant any immunity from penalty even if the assessee was able to show some reasonable cause in terms of section 273B of the Act as the provisions of section 273B specifically omits section 271AAB of the Act. Hence once the transaction

Shri Krushna Gau Seva Charitable Trust, Naliyeri Moli, Ta. Gir Gadhada, Dist. Junagadh vs. The CIT (Exemption) Ahmedabad, Ahmedabad

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

ITA 534/RJT/2025[2025-26]Status: DisposedITAT Rajkot11 Feb 2026AY 2025-26

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 534/Rjt/2025 ("नधा"रण वष" / Assessment Year: (2025-26) Shri Krushna Gau Seva Charitable Vs. Cit(Exemption), Trust, Room No.609, 6Th Floor, Aayakar Naliyeri Mol, Naliyeri Moli, Bhavan, Nr. Sachin Tower, 100Ft Ta. Gir Gadhada Road, Anandnagar-Prahladnagar Junagadh 362530 Road, Ahmedabad-380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aazts5830M (Appellant) (Respondent) Appellant By : Shri Jignesh Parikh, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) : 29/01/2026 Date Of Hearing Date Of Pronouncement : 11/02/2026 आदेश / O R D E R Per, Dr. Dinesh Mohan Sinha, Jm:

For Appellant: Shri Jignesh Parikh, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 12ASection 12A(1)(ac)

application filed under sub-clause (1) to (vi) of section 12A(1)(ac) of the Act can be condoned if there is a reasonable cause for delay in filing such application and notice you were given an opportunity to avail the benefit of such provisions introduced under ... explaining the reasonable cause for delay in filing the same along with necessary supporting evidence and affidavit.. However, you have not considered the same. In view of the above, you are once again requested to explain with corroborative evidences, condonation request/prayer and affidavit that why the present application filed

Jagdish Kanhaiyalal Khushalani, Nagpur vs. Income Tax Officer, Ward - 2(3) Nagpur, Nagpur

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

ITA 690/NAG/2025[2019-2020]Status: DisposedITAT Nagpur11 Feb 2026AY 2019-2020

Bench: Dr. Manish Borad

For Appellant: Shri Manoj G. Moryani, AdvFor Respondent: Shri Surjit Kumar Saha, Sr.DR
Section 154Section 250Section 50C

issue in accordance with law. The assessee is also directed to remain vigilant and not to take unnecessary adjournments unless otherwise required for reasonable cause. Effective grounds of 7 ITA.No.690/NAG/2025 (Jagdish Kanhaiyalal Khushalani) appeal raised by the assessee are allowed for statistical purposes. 10. In the result, appeal

State Bank of India Local Head Office Chandigarh, Chandigarh vs. Addl Commissioner of Income Tax(TDS) Chandigarh, Chandigarh

In the result, appeal filed by the Assessee is dismissed

ITA 991/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh11 Feb 2026AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 10(5)Section 133(6)Section 192Section 271C

facts and circumstances of the case the Ld.CIT(Appeals) NFAC has erred in having held that the assessee/appellant has not shown any reasonable cause that prevented it from deducting TI)S on the LTC/LFC payments. 4. On the facts and circumstances of the case the Ld.CIT(Appeals) NFAC has erred ... under section 271C is a civil liability and mens rea is not required for its imposition. It was observed that the burden to establish reasonable cause under section 273B lies entirely on the assessee and that the assessee failed to demonstrate any reasonable cause which prevented it from deducting

Deepak Kumar Prop. M/S Urvi Enterprises Mandigobindgarh, Mandi Gobindgarh vs. The Assessment Unit NFAC Delhi Jao the Income Tax Officer Ward-2 Mandi Gobindgarh, Mandi Gobindgarh

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

ITA 103/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh11 Feb 2026AY 2022-2023
For Appellant: Shri Rohit Garg, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR
Section 133(6)Section 142(1)Section 144Section 144BSection 250

that both the assessment proceedings as well as the first appellate proceedings were completed ex parte and that he was prevented by sufficient and reasonable cause from producing the relevant evidences before the lower authorities. The assessee submitted that he is an individual engaged in trading activities and was largely ... filing certain documents and, for this purpose, has moved an application for admission of additional evidence. In the said application, the assessee has disclosed reasonable cause explaining the non-filing of such documents before the lower authorities. 16. At the same time, we note that the Assessing Officer

Vikul Panchal, Ahmedabad vs. Income Tax Officer, Ahmedabad

In the result, the appeal (ITA No2138/Ahd/2025) filed by the assessee is allowed for statistical purposes

ITA 2340/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad11 Feb 2026AY 2013-14

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumarita No.2340/Ahd/2025 (Assessment Year : 2013-14)

For Appellant: Ms. Apporva Bhardwaj, ARFor Respondent: Shri Uday Kakne Kisanrao
Section 143(1)Section 147Section 148Section 271(1)(c)

denying an opportunity of being heard to the ITA Nos.2138 & 2340/Ahd/2025 Vikul Panchal vs. ITO Asst.Year - 2013-14 appellant without appreciating the genuine and reasonable cause for such delay. As such, the order may please be set aside to the Ld. AO for providing fair opportunity to the Appellant

Vikul Panchal, Ahmedabad, Gujarat vs. ITO, Ward 3(2)(10), Ahmedabad, Gujarat

In the result, the appeal (ITA No2138/Ahd/2025) filed by the assessee is allowed for statistical purposes

ITA 2138/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad11 Feb 2026AY 2013-14

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumarita No.2340/Ahd/2025 (Assessment Year : 2013-14)

For Appellant: Ms. Apporva Bhardwaj, ARFor Respondent: Shri Uday Kakne Kisanrao
Section 143(1)Section 147Section 148Section 271(1)(c)

denying an opportunity of being heard to the ITA Nos.2138 & 2340/Ahd/2025 Vikul Panchal vs. ITO Asst.Year - 2013-14 appellant without appreciating the genuine and reasonable cause for such delay. As such, the order may please be set aside to the Ld. AO for providing fair opportunity to the Appellant

Panchwadkar Shrihari Purshottam HUF, Solapur vs. Income Tax Officer Ward 2, Pandharpur

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

ITA 2928/PUN/2025[2017-18]Status: DisposedITAT Pune11 Feb 2026AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2928/Pun/2025 Assessment Year : 2017-18 Panchwadkar Shrihari Vs. Income Tax Officer, Purshottam Huf, Ward-2, Pandharpur 2085, Ashirvad Haridas Ves Pandharpur, Solapur – 413304 Maharashtra Pan : Aalhp4822N Appellant Respondent

For Appellant: NoneFor Respondent: Date of hearing
Section 142(1)Section 144Section 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. Impugned order is set aside and the effective grounds raised by the assessee are allowed for statistical purposes. 7. In the result, appeal

Shree Swami Samarth Annachhatra Mandal, Pune vs. Commissioner of Income Tax (Exemption), Pune

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

ITA 2740/PUN/2025[2025-26]Status: DisposedITAT Pune11 Feb 2026AY 2025-26

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2740/Pun/2025 Shree Swami Samarth Vs. Cit (Exemption) Annachhatra Mandal, Pune A & P Akkalkot, Dist. Solapur 413 216, Maharashtra Pan : Aaats 5556M Appellant Respondent

For Appellant: Shri Sharaz A VazeFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

make satisfactory compliance to the notice(s) of hearing issued by ld.CIT(Exemption). It should refrain from taking adjournments unless otherwise required for reasonable cause. Effective grounds of appeal raised by the appellant are allowed for statistical purposes. 7. In the result, the appeal of the appellant is allowed

St George Orthodox Syrian Church Chinchwad, Pune vs. CIT (E), Pune

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

ITA 2708/PUN/2025[2023-24]Status: DisposedITAT Pune11 Feb 2026AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2708/Pun/2025 St. George Orthodox Syrian Vs. Cit (Exemption) Church, Pune S.No.35/3/1, Dattawadi, Akurdi, Pune 411035 Maharashtra Pan : Aarts3501P Appellant Respondent

For Appellant: Shri B.S. RajpurohitFor Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)

Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987) 2 SCC 107) we find that due to ‘reasonable cause’ appellant failed to file the appeal within the time limit specified under the Act. We therefore condone the delay of 322 days in filing the appeal ... make satisfactory compliance to the notice(s) of hearing issued by ld.CIT(Exemption). It should refrain from taking adjournments unless otherwise required for reasonable cause. Effective grounds of appeal raised by the appellant are allowed for statistical purposes. 8. In the result, the appeal of the appellant is allowed

Mumatajabi Yasin Sayyad, Beed vs. CIT(A), Aurangabad

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

ITA 2699/PUN/2025[2015-16]Status: DisposedITAT Pune11 Feb 2026AY 2015-16

Bench: Dr.Manish Boradआयकर अपील सं. / Ita Nos.2699 & 2698/Pun/2025 Assessment Year : 2015-16 Mumatajabi Yasin Sayyad, Vs. Income Tax Officer, Krantinagar, Patoda, Ward -1(5), Beed-414204 Aurangabad Maharashtra Pan : Codps6590A Appellant Respondent

For Appellant: Shri Shubham RathiFor Respondent: Shri Eknath Abhang
Section 250Section 271(1)(c)Section 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 appeals within the time limit specified under the Act. I therefore condone the delay of 235 days and 84 days respectively ... afford 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. Impugned order is set aside and all the grounds of appeal raised by the assessee are allowed for statistical purposes. 9. Since the issues