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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

S.N. Exports, New Delhi vs. ITO Ward-4, Panipat

In the result, all the appeals of Revenue are dismissed

ITA 2359/DEL/2019[2014-15]Status: DisposedITAT Delhi09 May 2025AY 2014-15

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: NoneFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 143(3)Section 271GSection 92BSection 92DSection 92D(1)

under: - “31 The assessee had also contended in its submission that penalty u/s 271G cannot be levied if there was reasonable cause for failure to furnish information called for by the TPO. From the above contention, it is clear that, finally, assessee has taken shelter u/s 273B of the Income ... person or the assessee, as the case may be, for any failure referred to in the said provisions if he proves that there was reasonable cause for the said failure." 31.1. But, in the instant case, assessee has not made a reasonable cause for failure to maintain documentation prescribed under

S.N. Exports, New Delhi vs. ITO Ward-4, Panipat

In the result, all the appeals of Revenue are dismissed

ITA 2358/DEL/2019[2014-15]Status: DisposedITAT Delhi09 May 2025AY 2014-15

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: NoneFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 143(3)Section 271GSection 92BSection 92DSection 92D(1)

under: - “31 The assessee had also contended in its submission that penalty u/s 271G cannot be levied if there was reasonable cause for failure to furnish information called for by the TPO. From the above contention, it is clear that, finally, assessee has taken shelter u/s 273B of the Income ... person or the assessee, as the case may be, for any failure referred to in the said provisions if he proves that there was reasonable cause for the said failure." 31.1. But, in the instant case, assessee has not made a reasonable cause for failure to maintain documentation prescribed under

Rrb Energy Ltd., New Delhi vs. Addl. CIT, Range- 15, New Delhi

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

ITA 4104/DEL/2017[2011-12]Status: DisposedITAT Delhi09 May 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 253(5)Section 35

presenting the appeal within the prescribed time. The explanation of the assessee therefore, becomes relevant to determine whether the same reflects sufficient and reasonable cause on its part in not presenting the present appeal within the prescribed time. 6. In case of Collector, Land Acquisition vs MST Katiji (Supra ... more so considering the fact of the case. Therefore, in the factual matrix of the present case, we find that there exists sufficient and reasonable cause for condoning the delay in filing this appeal and as held by the Hon’ble Supreme Court, where substantial justice and technical considerations

Assistant Commissioner of Income-Tax, Circle-3(1)(1), Ahmedabad vs. Mahesh Mohanbhai Patel(HUF), Ahmedabad

In the result the appeal filed by the Revenue is dismissed

ITA 1147/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad08 May 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2020-21

For Appellant: None
Section 143(1)Section 143(1)(a)Section 250

appeal before the CIT(A). The assessee also sought condonation of delay in filing the appeal, which was accepted by the CIT(A) citing reasonable cause due to illness during the COVID-19 pandemic. Before the CIT(A), the assessee contended that the amount of Rs.4

Atul Limited, Ahmedabad vs. The ACIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal is partly allowed

ITA 38/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Bandish Soparkar, AR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 35Section 40Section 9(1)(vii)Section 92C

resignation documentation, and taking into account the principle of natural justice, we are satisfied that the delay was due to a bonafide and reasonable cause. The learned Departmental Representative (DR) raised no objection for condonation of delay. Hence, the delay of 86 days is condoned, and the appeal is admitted

Sangram Punyasathi Foundation, Pune vs. CIT, Pune

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

ITA 504/PUN/2025[2024-25]Status: DisposedITAT Pune08 May 2025AY 2024-25

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.504/Pun/2025

For Appellant: Shri Anand KhandelwalFor Respondent: Shri Ajay Kumar Keshari
Section 12A

Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987) 2 SCC 107) we find that there was ‘reasonable cause’ in not filing the appeal within the 2 Sangram Punyasathi Foundation time limit specified under the Act. We therefore condone the delay of 25 days ... after affording reasonable opportunity to the assessee. Assessee is directed to remain vigilant and not to take unnecessary adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised on merits by the assessee are allowed for statistical purposes. 4 Sangram Punyasathi Foundation 8. In the result, appeal

Harishchandra Shreepat Bhane, Mumbai vs. Income Tax Officer Ward 3(4), Mumbai

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

ITA 1607/MUM/2025[2011-12]Status: DisposedITAT Mumbai08 May 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosainharishchandra Shreepat Vs. Ito – 3(4) Bhane Niwas, Jitendra Wadi Kalyan At Adivli Goan, Post Dwarli Goan, Ambernath, Thene Dist. Pan/Gir No. Arfpb7179 (Applicant) Respondent) Assessee By Shri Mahaveer Jain Revenue By Shri Avinash Karpe, Sr. Dr Date Of Hearing 01.05.2025 Date Of Pronouncement 08.05.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 30.08.2023 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2011-12. 2. At The Very Outset I Noticed That There Is A Delay Of 493 Days In Filing The Present Appeal By The Assessee . In This Regard Ld. Ar Has Filed An Application For Seeking

Section 250

that as it may, without going into the merits of the issues raised by the assessee and considering the fact that there was reasonable cause, because of which assessee could not put effective representation before AO and Ld. CIT(A). Hence the Bench is of the view that one more

Saroj Mahendrakumar Agarwal, Mumbai vs. Income Tax Officer- 25(3)(4), Mumbai

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

ITA 1605/MUM/2025[2011-12]Status: DisposedITAT Mumbai08 May 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosainsaroj Mahendra Kumar Vs. Ito – 25(3)(4) Agarwal Kautilya Bhawan, Bkc, 5/A, Pravin Bldg, Sundervan Bandra East, Mumbai – Chs, S.V. Road, Vile Parle 400051. (W), Mumbai – 400056. Pan/Gir No. Aabpa0184A (Applicant) Respondent) Assessee By Shri Rakesh Joshi Revenue By Shri Avinash Karpe, Sr. Dr Date Of Hearing 01.05.2025 Date Of Pronouncement 08.05.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 09.01.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2011-12. 2. At The Very Outset I Noticed That There Is A Delay Of 340 Days In Filing The Present Appeal By The Assessee . In This Regard Ld. Ar Has Filed An Application For Seeking

Section 250

that as it may, without going into the merits of the issues raised by the assessee and considering the fact that there was reasonable cause, because of which assessee could not put effective representation before Ld. CIT(A). Hence the Bench is of the view that one more opportunity

Didwana Vikash Parishad Samiti, Didwana, Nagaur vs. AO, NFAC, Jodhpur

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

ITA 172/JODH/2024[2018-19]Status: DisposedITAT Jodhpur07 May 2025AY 2018-19

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 133(6)Section 143(3)

where the contents are supported with an affidavit that remained uncontroverted by the Ld. DR. According, we hold that the appellant has prima facie reasonable cause for the delay of 23 days in filing the appeal and we therefore condone the said delay and admit the appeal for hearing

Surya Realcon Private Limited, Saraidhela, Dhanbad vs. DCIT, Aayakar Bhawan, Dhanbad

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

ITA 5/RAN/2024[2019-20]Status: DisposedITAT Ranchi07 May 2025AY 2019-20

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 139Section 139(1)Section 139(4)Section 143(1)(a)Section 801Section 801B

Doctor's Certificate enclosed). The situation was beyond of his control. 6. That there is no malafIde intention behind it. 7. That there is reasonable cause for non -filing the return in due time. 8. That merely on the ground that return has been filed belatedly the exempt U/s 801B ... entitled for deduction. 17. That the Act does not prohibit relief when genuine hardship is faced. 18. That the assessee was prevented by a reasonable cause as attributed by it in furnishing its return of income belatedly. 19. That it is clear that the provision contained in s. 80AC

Surya Realcon Private Limited, Saraidhela, Dhanbad vs. DCIT, Aayakar Bhawan, Dhanbad

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

ITA 4/RAN/2024[2018-19]Status: DisposedITAT Ranchi07 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 139Section 139(1)Section 139(4)Section 143(1)(a)Section 801Section 801B

Doctor's Certificate enclosed). The situation was beyond of his control. 6. That there is no malafIde intention behind it. 7. That there is reasonable cause for non -filing the return in due time. 8. That merely on the ground that return has been filed belatedly the exempt U/s 801B ... entitled for deduction. 17. That the Act does not prohibit relief when genuine hardship is faced. 18. That the assessee was prevented by a reasonable cause as attributed by it in furnishing its return of income belatedly. 19. That it is clear that the provision contained in s. 80AC

Shishu Kalyan Shikkha Samiti, Mahasamund vs. Income Tax Officer, Exemption Ward, Raipur

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

ITA 164/RPR/2025[2014-15]Status: DisposedITAT Raipur07 May 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.164/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Shishu Kalyan Shikkha Samiti Panchsheel Nagar, Mahasamund, Chhattisgarh-493 445 Pan: Aants0821N ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Exemption Ward, Raipur (C.G) ……""यथ" / Respondent

For Appellant: Mrs. Dimple Warlyani, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 10Section 139Section 250(4)Section 272A(2)(e)

That as per record, the assessee had put the blame on the department for issuing notice after 8 years rather than explaining the reasonable cause that why such penalty should not be levied on the assessee. Therefore, the assessee shall also explain as to why the said penalty should

Shree Pipardi Seva Sahakari Mandali Limited, Surendranagar vs. The ITO Ward-2 (1) (2), Rajkot

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

ITA 448/RJT/2024[2019-20]Status: DisposedITAT Rajkot07 May 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 448/Rjt/2024 Assessment Year: (2019-20)

Section 143(1)Section 153Section 249(2)Section 80P

448/Rjt/2024 Sh. Pipardi Seva Shakari Mandli Ltd. addition made by Assessing Officer was confirmed. The Ld. AR of the assessee submits that there was reasonable cause for condonation of delay. In fact, the assessment was completed u/s 143(1) of the Act. The Ld. AR of the assessee submitted that

Shaikh Abid Shaikh Zahoor L/H of Jahur Kamruddin Bhisti, Jalgaon vs. ITO Ward 1(3), Jalgaon

ITA 620/PUN/2025[2011-12]Status: DisposedITAT Pune07 May 2025AY 2011-12
Section 250

issued by him and thereby erred in confirming the various additions made by the learned A.O. 2] The assessee submits that there was a reasonable cause on his part for the non-compliance to the notices issued by the learned CIT(A) and accordingly, request for one more opportunity

Rameshwardas Shivcharandas and Company, Nanded vs. ITO Ward 1, Jalna

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

ITA 524/PUN/2025[2015-16]Status: DisposedITAT Pune07 May 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.524/Pun/2025 Assessment Year : 2015-16

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Ganesh B Budruk
Section 139(1)Section 147Section 148Section 250Section 282

receiving the notices from ITBA portal. Assessee is also directed to remain vigilant and not to take unnecessary adjournment unless otherwise required for reasonable cause. Grounds of appeal raised by the assessee are allowed for statistical purposes. 7. In the result, appeal of the assessee is allowed for statistical purposes

Warangal Club, Hanamkonda vs. ITO, Ward-1, Warangal

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

ITA 109/HYD/2025[2015-16]Status: DisposedITAT Hyderabad07 May 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Smt. S. Sandhya, AdvocateFor Respondent: Shri D. Praveen, Sr. AR
Section 142(1)Section 147Section 148Section 249(4)Section 249(4)(b)

appellant-club seeking for condonation of delay of 27 days in filing the appeal before the Tribunal. Since there is a ‘sufficient and reasonable cause’ for the appellant- club in not filing the appeal before the Tribunal within the prescribed time and we are satisfied with the reasons furnished

Monish Ranjan Dasgupta, Kolkata vs. ITO, Ward - 61(3), Kolkata

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

ITA 2447/KOL/2024[2016-17]Status: DisposedITAT Kolkata07 May 2025AY 2016-17

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 148Section 250Section 271(1)Section 271(1)(c)Section 80

laws. Due to late receipt of information, the time gap between date of order and date of filing of appeal arises. There being reasonable cause for delay in filing of this appeal as compared from the date of the appeal order, the assessee prays for condonation of the delay

Ritu Verma, Thane vs. Income Tax Officer, Thane

ITA 377/MUM/2025[2013-14]Status: DisposedITAT Mumbai07 May 2025AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Abhimanyu JambaFor Respondent: Shri R.R. Makwana
Section 142(1)Section 143(1)Section 144Section 147Section 250Section 271(1)(b)Section 273B

medical reports show that she was undergoing medical treatment at the relevant point of time. Therefore, we hold that the Assessee was prevented by reasonable cause from complying with the notice under Section 142(1) of the Act and the default committed by the Assessee was not deliberate. Accordingly

Bharatbhai Ravatbhai Khachar, Rajkot vs. The ITO, Ward 1(2)(1), Rajkot

ITA 263/RJT/2024[2016-17]Status: DisposedITAT Rajkot06 May 2025AY 2016-17
For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 26Section 269Section 269SSection 271DSection 274

discussion, I find no infirmity in the action of imposing penalty u/s 271D in the appellant's case. The appellant has not demonstrated any reasonable cause for violating the provisions of section 269SS of the Act. The transactions are clearly involution of section 269SS of the Act and therefore

Kanhiya Lal Choudhary, Todaraisingh vs. Commissioner of Incometax Appeals, Incometax Department Face Less

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

ITA 178/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 May 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 178/JPR/2025 निर्धारणवर्ष / Assessment Year: 2018-19 Shri Kanhiya Lal Choudhary Near Bus Stand, Todaraisingh Tonk Road, 304 001 बनाम Vs. DCIT Circle-7 Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABAPC 0831 G अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri K.L. Moolchandani, ITP राजस्व की ओरसे / Revenue by: Shri Gautam Singh Choudhary, Addl.CIT-DR Thru' VC सु

For Appellant: Shri K.L. Moolchandani, ITPFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT-DR
Section 250Section 69C

circumstances of the case, judicial principles laid down by the above quoted judgements, it is clear that appellant has failed to furnish sufficient and reasonable cause explaining the delay, hence the instant appeal filed after the expiry of due date is barred by limitation and not admitted ... your kind perusal and record. 2. Having considered the above facts, your honors may appreciate that the Appellant was prevented by honest and reasonable cause from filing the present, your honous are therefore, requested to kindly condone the delay and admit the same in the interest of equity and natural