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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

D S Kulkarni and Company, Pune vs. DCIT Circle 2, Pune

In the result, both the appeals of the assessee in ITA Nos

ITA 2419/PUN/2024[2014-15]Status: DisposedITAT Pune30 Apr 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2417 To 2421/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2016-17 D. S. Kulkarni & Vs. Dcit, Cricle-2, Pune Company, Flat No.701, Modi Baug, Dsk Haryali, Shivajinagar, Pune- 411016. Pan : Aaefd2122L Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amol Khairnar Date Of Hearing : 19.02.2025 Date Of Pronouncement : 30.04.2025 आदेश / Order Per Bench: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 24.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14, 2014-15 & 2016-17 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2418/Pun/2024 For Assessment Year 2016-17 As A Lead Case For Adjudication.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amol Khairnar
Section 147Section 148

thereby erred in confirming the addition of Rs.29,35,06,820/- made by the learned A.O. 2] The assessee submits that there was a reasonable cause on its part for the non compliance to the notices issued by the learned CIT(A) and accordingly, requests for one more opportunity ... resulted in ex-parte orders passed by the subordinate authorities. It was therefore submitted by Ld. AR of the assessee that the assessee has reasonable cause for non-compliance to the notices issued by Ld. CIT(A)/NFAC and therefore he requested for one more opportunity to substantiate its case

D S Kulkarni and Company, Pune vs. DCIT Circle 2, Pune

In the result, both the appeals of the assessee in ITA Nos

ITA 2418/PUN/2024[2016-17]Status: DisposedITAT Pune30 Apr 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2417 To 2421/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2016-17 D. S. Kulkarni & Vs. Dcit, Cricle-2, Pune Company, Flat No.701, Modi Baug, Dsk Haryali, Shivajinagar, Pune- 411016. Pan : Aaefd2122L Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amol Khairnar Date Of Hearing : 19.02.2025 Date Of Pronouncement : 30.04.2025 आदेश / Order Per Bench: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 24.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14, 2014-15 & 2016-17 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2418/Pun/2024 For Assessment Year 2016-17 As A Lead Case For Adjudication.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amol Khairnar
Section 147Section 148

thereby erred in confirming the addition of Rs.29,35,06,820/- made by the learned A.O. 2] The assessee submits that there was a reasonable cause on its part for the non compliance to the notices issued by the learned CIT(A) and accordingly, requests for one more opportunity ... resulted in ex-parte orders passed by the subordinate authorities. It was therefore submitted by Ld. AR of the assessee that the assessee has reasonable cause for non-compliance to the notices issued by Ld. CIT(A)/NFAC and therefore he requested for one more opportunity to substantiate its case

D S Kulkarni and Company, Pune vs. DCIT Circle 2, Pune

In the result, both the appeals of the assessee in ITA Nos

ITA 2417/PUN/2024[2016-17]Status: DisposedITAT Pune30 Apr 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2417 To 2421/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2016-17 D. S. Kulkarni & Vs. Dcit, Cricle-2, Pune Company, Flat No.701, Modi Baug, Dsk Haryali, Shivajinagar, Pune- 411016. Pan : Aaefd2122L Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amol Khairnar Date Of Hearing : 19.02.2025 Date Of Pronouncement : 30.04.2025 आदेश / Order Per Bench: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 24.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14, 2014-15 & 2016-17 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2418/Pun/2024 For Assessment Year 2016-17 As A Lead Case For Adjudication.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amol Khairnar
Section 147Section 148

thereby erred in confirming the addition of Rs.29,35,06,820/- made by the learned A.O. 2] The assessee submits that there was a reasonable cause on its part for the non compliance to the notices issued by the learned CIT(A) and accordingly, requests for one more opportunity ... resulted in ex-parte orders passed by the subordinate authorities. It was therefore submitted by Ld. AR of the assessee that the assessee has reasonable cause for non-compliance to the notices issued by Ld. CIT(A)/NFAC and therefore he requested for one more opportunity to substantiate its case

Rajkunwar Bahuudeshiya Sevabhavi Sanstha, Jalna vs. CIT (E), Pune

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

ITA 1468/PUN/2024[-]Status: DisposedITAT Pune30 Apr 2025

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1468/Pun/2024 Rajkunwar Bahuuddeshiya Vs. Cit, Exemption, Pune. Sevabhavi Sanstha, Yashwant Nagar, Ambad Road, Jalna- 431203. Pan : Aactr4529B Appellant Respondent Assessee By : Shri Shubham N. Rathi Revenue By : Shri Ajay Kumar Keshari Date Of Hearing 21.04.2025 : Date Of Pronouncement 30.04.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2024 Passed By Ld. Cit, Exemption, Pune Rejecting The Application For Registration U/S 12Ab Of The It Act. 2. There Is A Delay Of 110 Days In Filing Of The Present Appeal. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Along With An Affidavit. We Are Satisfied With The Explanation Of The Assessee That He Was Prevented By Reasonable Cause For Not Filing The Present Appeal Within Prescribed Time Limit. Ld. Dr Raised No Serious Objection To The Condonation Request

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Ajay Kumar Keshari
Section 12ASection 12A(1)(ac)Section 12A(1)(as)Section 36ASection 36A(3)

application for condonation of delay along with an affidavit. We are satisfied with the explanation of the assessee that he was prevented by reasonable cause for not filing the present appeal within prescribed time limit. Ld. DR raised no serious objection to the condonation request 2 made by the assessee

M/S. Alert Security Services, Coimbatore vs. DCIT, Ncc-4, Coimbatore

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

ITA 586/CHNY/2025[2018-19]Status: DisposedITAT Chennai30 Apr 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.586/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Alert Security Services, Vs. The Deputy Commissioner Of 106, Sowrimuthu Street, Red Fields, Income Tax, Coimbatore 641 045. Non Corporate Circle 4, [Pan:Aasfa2624E] Coimbatore. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri M.P. Guru Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 22.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.11.2022 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 765 Days. The Assessee Filed An Affidavit For Condonation Of Delay By Stating Following Reasons: 1. That The Petitioner Operates As A Partnership Firm Under The Trade Name M/S. Alert Security Services Filed His Return Of Income For The Said Assessment Year On 2

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri M.P. Guru Prasad, Addl. CIT
Section 143(3)Section 250

reason. Thus, the ld. DR pleaded that the huge delay in filing the appeal should not be condoned since the assessee failed to establish reasonable cause for the delay with documentary evidence. 5. We have heard both the parties and perused the affidavit filed for condonation of delay ... assessee could not produce any documentary evidence in the form of medical certificate. We note that the assessee 4 I.T.A. No.586/Chny/25 could not establish reasonable cause for the delay with any piece of evidence. Under the above facts and circumstances of the case, we are of the opinion that

Karuna Evam Shanti Vahini Foundation, Mumbai vs. CIT(Exemption), Mumbai

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

ITA 1497/MUM/2025[Not Applicable]Status: DisposedITAT Mumbai30 Apr 2025

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhankaruna Evam Shanti Vahini Cit (Exemptions) Foundation, 601, 6Th Floor, 12/A, Florida Apartment, Vs. Cumballa Hills, Mound Mary Road, Pedder Road, Bandra (West), Mumbai-400026. Mumbai-400050. Pan : Aajck6283D (Appellant) (Respondent)

For Appellant: Shri Samir VoraFor Respondent: Shri Biswanath Das, CIT-DR
Section 12ASection 12A(1)(ac)Section 7(2)Section 80G

appeal as pointed out by the Registry. After hearing both the parties and perusing the facts placed on record, we find that there was reasonable cause for the delay in filing the present appeal and hence, the delay is hereby condoned and appeal is admitted for adjudication. 3. During

Akshay Arun Shetty, Mumbai vs. Income Tax Officer-2, Panvel

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

ITA 1310/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Apr 2025AY 2013-14

Bench: Shri Pawan Singh, Hon’Bleakshay Arun Shetty Ito – 2 Panvel - 410206 Flat No. 6, 3Rd Floor, Shree Chs, Maharashtra. Sector 3E, Kalamboli, Vs Navi Mumbai – 410218 Maharashtra

Section 144Section 254(1)Section 69A

filing the appeal before ld. CIT(A). Assessment was completed on 23.09.2021 and appeal was filed on 19.04.2023. The assessee has not shown any reasonable cause for condonation of delay. Assessee is relying on self-serving story. Sr. DR submitted that delay cannot be condoned. On merit

Amita Dutta, Thane vs. Income Tax Officer, Thane

In the result, substantial ground of appeal raised by the assessee is allowed for statistical purpose

ITA 1229/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Apr 2025AY 2011-12

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 144Section 147Section 148Section 234ASection 254(1)Section 46ASection 69

assessment order is a copy of certified copy, attested by ITO, ward-1(1) Noida, on 22.07.2020. Thus, the assessee has shown sufficient and reasonable cause for filing appeal belatedly. I find that such fact is not considered by CIT(A) though all such facts are narrated in Form ... column of statement of facts. The ld. CIT(A) conveniently ignore such fact. On independent consideration of such fact that the assessee has shown reasonable cause for not filing appeal within 30 days from passing the assessment order, rather the assessee has filed appeal within 30 days from receipt

Jaimin S Patel, Bharuch vs. ACIT, Circle 3(1)(1), Mumbai

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

ITA 6886/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Apr 2025AY 2017-18

Bench: Shri Pawan Singh(Hybrid Hearing) Jaimin S. Patel Acit – Circle – 3(1)(1) Room No. 607, 6Th Floor 135 Patel Faliyu, Itkala Valid Bharuch Aayakar Bhavan, M.K. Gujarat – 393135 Vs Road, Mumbai- 400020 Pan. Aiopp 2429 E Maharashtra Appellant (Respondent) Assessee Represented By : Shri Rasesh Shah Fca & Shri Brijesh Vyas Department Represented By : Ms. Pradnya Gholap, Sr. Dr Date Of Conclusion Of Hearing : 17.04.2025 Date Of Pronouncement Of Order : 30.04.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh;

Section 115BSection 144Section 254(1)Section 68

filed medical certificate. On considering all the facts and the submissions of ld AR of the assessee, find that the assessee had shown reasonable cause for condoning delay in filing appeal before ld CIT(A). Further, by filing the appeal belatedly the assessee is not going to be benefited rather

M/S. Bharat Coking Coal Limited, Dhanbad vs. JCIT TDS, Dhanbad

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

ITA 77/RAN/2024[2010-11]Status: DisposedITAT Ranchi29 Apr 2025AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 194ASection 201Section 271CSection 273BSection 40

view of the case the appellant was under bonafide belief that no TDS is deductible on such interest and as such there was reasonable cause for the alleged failure to deduct TDS within the meaning of section 273B of the Act. 6. For that the appellant craves leave ... deposited. Thus, the assessee was under bonafide belief that no TDS is required to be made on such hypothetical interest. This constitutes a reasonable cause. vii. That since the same were duly allowed as expenditure, the assessee offered to tax the same in AY 2014-15 as cessation of liability

M/S. Bharat Coking Coal Limited, Dhanbad vs. JCIT, TDS Circle, Dhanbad

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

ITA 76/RAN/2024[09-10]Status: DisposedITAT Ranchi29 Apr 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 194ASection 201Section 271CSection 273BSection 40

view of the case the appellant was under bonafide belief that no TDS is deductible on such interest and as such there was reasonable cause for the alleged failure to deduct TDS within the meaning of section 273B of the Act. 6. For that the appellant craves leave ... deposited. Thus, the assessee was under bonafide belief that no TDS is required to be made on such hypothetical interest. This constitutes a reasonable cause. vii. That since the same were duly allowed as expenditure, the assessee offered to tax the same in AY 2014-15 as cessation of liability

M/S. Bharat Coking Coal Limited, Dhanbad vs. Jt. CIT, TDS, Dhanbad

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

ITA 75/RAN/2024[08-09]Status: DisposedITAT Ranchi29 Apr 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 194ASection 201Section 271CSection 273BSection 40

view of the case the appellant was under bonafide belief that no TDS is deductible on such interest and as such there was reasonable cause for the alleged failure to deduct TDS within the meaning of section 273B of the Act. 6. For that the appellant craves leave ... deposited. Thus, the assessee was under bonafide belief that no TDS is required to be made on such hypothetical interest. This constitutes a reasonable cause. vii. That since the same were duly allowed as expenditure, the assessee offered to tax the same in AY 2014-15 as cessation of liability

Rahul Coal India Private Limited, Surat vs. ITO TDS-2, Surat

In the result, appeal of the assessee is allowed

ITA 1220/SRT/2024[2013-14]Status: DisposedITAT Surat29 Apr 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1220/Srt/2024 Assessment Year: (2013-14) (Physical Hearing) Rahul Coal India Pvt. Ltd. Vs. The Addl. Cit (Tds), 429-432 Golden Point, Ring Road, Surat, Nr. Bsnl Office, Surat-395 002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcr1044D (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 18/02/2025 Date Of Pronouncement 29/04/2025

Section 133ASection 201(1)Section 206Section 206CSection 206C(1)Section 250Section 271CSection 271C(1)(a)

with the TCS provisions of the Act. He held the appellant as assessee in default because it contravened provisions of section 206C(1) without reasonable cause. He levied penalty of Rs.87,750/- u/s 271CA of the Act vide order dated 25.02.2022. 3. Aggrieved by the order of AO, the assessee ... Authorized Representative (ld. AR) of the assessee filed a paper book and submitted that assessee did not receive any notice and hence there was reasonable cause for failure to comply with notice u/s 271CA of the Act. He submitted that assessee was residing at 429 - 432, Golden Point, Falsawadi

Sanjay Kumar Bomb Legal Heir of Late Shri Ajit Kumar Bomb, Neemuch vs. Income Tax Officer Neemuch, Neemuch

Appeal is disposed off in effective manner and not as

ITA 907/IND/2024[2013-14]Status: DisposedITAT Indore29 Apr 2025AY 2013-14

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshisanjay Kumar Bombl/H Of Income Tax Officer, बना Late Ajit Kumar Bomb, Neemuch म/ 18, Bunglow No.41, Vs. Bhuteshwar Mandir Road, Neemuch (Pan: Aappb8200L) (Appellant) (Revenue) Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.04.2025 Date Of Pronouncement 29.04.2025 आदेश/ O R D E R

Section 147Section 148Section 246ASection 250Section 253Section 271(1)(c)

appeal has happened due to aforesaid reason. An affidavit too is prepared in support. It was prayed that delay be condoned as genuine and reasonable cause is shown. We have carefully perused the condonation of delay application dated 19.12.2024. We notice that “impugned order” is dated 09.02.2024 and that appeal ... registry. The Ld. DR has not opposed condonation of delay application. Under the circumstances we are of the considered view that assessee has shown reasonable cause and accordingly we condone the delay and admit the appeal. 2.2 That as and by way of an assessment order made u/s 147 r.w.s

Sandeep Kumar Yadav, Betul vs. National Faceless Assessment Centre, Delho

The appeal of the appellant is dismissed for statistical purpose

ITA 501/IND/2024[2013-14]Status: DisposedITAT Indore29 Apr 2025AY 2013-14

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshisandeep Kumar Yadav, Nfac, बना Palsyapalsya, Delhi म/ Palsya, Vs. The. Bhainsdehi, Betul (Pan: Afnpy3295D) (Appellant) (Revenue) Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.04.2025 Date Of Pronouncement 29.04.2025 आदेश/ O R D E R

Section 131Section 133(6)Section 139(4)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 253Section 271(1)(b)

presenting the appeal within the time period prescribed u/s 249(2) of the Act.) 4. According to the appellant, there is reasonable cause for filing the appeal belatedly. The delay was not willful but due to the circumstances beyond the control of the assessee. The reason stated by the appellant ... event. Merely because substantial justice is to be done law of limitation cannot be ignored and that also when there is no sufficient and reasonable cause for such inordinate delay. Page 11 of 13 Sandeep Kumar Yadav ITA No. 501/Ind/2024 - A.Y.2013-14 6.1. The appellant, in the present situation, appears

Ranjan Sharma, Jaipur vs. ITO Ward 6(2), Jaipur

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

ITA 239/JPR/2025[2014-15]Status: DisposedITAT Jaipur29 Apr 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri R.S. Poonia, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 40A(3)Section 56(2)(vii)

delay in filing of appeals which is beyond my control. In view of above submission you are requested that kindly consider this as reasonable cause to condone the delay of 447 days in both the appeals. So, that proper inquiry can be conducted and substantial justice may be delivered

Ranjan Sharma, Jaipur vs. ITO WD 6(2), Jpr, Jaipur

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

ITA 238/JPR/2025[2010-11]Status: DisposedITAT Jaipur29 Apr 2025AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri R.S. Poonia, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 40A(3)Section 56(2)(vii)

delay in filing of appeals which is beyond my control. In view of above submission you are requested that kindly consider this as reasonable cause to condone the delay of 447 days in both the appeals. So, that proper inquiry can be conducted and substantial justice may be delivered

Seth Rb Moondhra Memorial Charitable Trust, Bani Park, Jaipur vs. CIT Exemption(1), Jaipur

In the result the appeal of the assessee is allowed

ITA 610/JPR/2024[2013-14]Status: DisposedITAT Jaipur29 Apr 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Mrs. Prabha Rana, Advocate &For Respondent: Shri Gautam Singh Choudhary
Section 11(1)(a)Section 11(5)Section 12ASection 2

which delayed by 1672 days. The ld. CIT(A) has not deemed it fit that the delay was on account of the reasonable cause not therefore, the appeal was considered as non- maintainable being out of time and thus the appeal was dismissed. 4. Aggrieved with that order

Wasim Akram, Sikar vs. Income Tax Officer, Sikar

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

ITA 1314/JPR/2024[2017-18]Status: DisposedITAT Jaipur29 Apr 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Mrs. Vipula Kumari, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT a
Section 142(1)Section 144

that the appellant was not serious and his attitude was non- cooperative, is wholly incorrect and in disregard of the fact that there was reasonable cause for alleged non-compliance on the dates fixed for hearing. The appellant’s business of phone recharge was not in good condition, because

Sureshbhai Ranchhodbhai Patel, Ahmedabad vs. ACIT Circle 6(1), Ahmedabad

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

ITA 1328/AHD/2024[2017-2018]Status: DisposedITAT Ahmedabad29 Apr 2025AY 2017-2018

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1327 & 1328/Ahd/2024 ("नधा"रण वष" / Assessment Year: 2016-17 & 2017-18) बनाम/ Sureshbhai Ranchhodbhai Acit Circle 5(2)(1), Ahmedabad Patel Vs. 1, Shayona Darshan & Bunglow, Opp. Gujarat High Court, Ghatlodia, Acit, Circle 6(1), Gujarat – 380061 Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Actpp1167A (Appellant) .. (Respondent) Assessee By : Shri R B Tank, A.R. Shri Kavan Limbasiya, Sr. Dr Revenue By : 26/03/2025 Date Of Hearing Date Of Pronouncement 29/04/2025

For Appellant: Shri R B Tank, A.RFor Respondent: 26/03/2025
Section 143(3)Section 56Section 56(2)(vii)Section 57

record the death certificate of his counsel Shri Harishkumar Shanabhai Patel, as per which, he had expired on 07.09.2023. Therefore, we find a reasonable cause for non- compliance before the Ld. CIT(A) on the last date of hearing. In the interest of justice, we, therefore, set aside both