“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

Associated Cement Products, Nagpur vs. ITO Ward 4(1), Nagpur

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

ITA 612/NAG/2025[2019-20]Status: DisposedITAT Nagpur10 Feb 2026AY 2019-20

Bench: Dr. Manish Borad

For Appellant: Shri Kapil Bahri, CAFor Respondent: Shri Surjit Kumar Saha, Sr. DR

Section 147Section 250Section 250(6)

fair hearing of opportunity to the assessee. Assessee is also directed to remain vigilant and not to take unnecessary adjournments unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. 6. In the result, appeal of the Assessee is allowed

Adds Aquaculture Private Limited, Nagpur vs. ITO Ward 4(4), Nagpur

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

ITA 577/NAG/2025[2017-18]Status: DisposedITAT Nagpur10 Feb 2026AY 2017-18

Bench: Dr. Manish Borad

For Appellant: Shri Abhay Agrawal, AdvocateFor Respondent: Shri Surjit Kumar Saha, Sr.DR

Section 139Section 144Section 148Section 250

contents of the affidavit and the 2 ITA.No.577/NAG/2025 (ADDS Aquaculture Pvt. Ltd.) reasons stated for delay and find that the same are reasonable cause and the assessee had bonafide reason giving rise to this delay and also find that the delay is not intentional and that the assessee ... issues 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 appeal raised by the assessee are allowed for statistical purposes. 7. In the result, appeal of the Assessee is allowed for statistical

Ashish Bhagwan Balpande, Nagpur vs. ITO Ward 4(4), Nagpur

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

ITA 567/NAG/2025[2015-16]Status: DisposedITAT Nagpur10 Feb 2026AY 2015-16

Bench: Dr. Manish Borad

For Appellant: Shri Dilip Lohiya, CAFor Respondent: Shri Surjit Kumar Saha, Sr.DR

Section 143(3)Section 250Section 250(6)Section 69

Bhagwan Balpande) delay. I have gone through the contents of the affidavit and the reasons stated for delay and find that the same are reasonable cause and the assessee had bonafide reason giving rise to this delay and also find that the delay is not intentional and the assessee ... contemplated u/s. 250(6) of the Act. The assessee is also directed to remain vigilant and not to take unnecessary adjournments unless required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. 4 ITA.No.567/NAG/2025 (Ashish Bhagwan Balpande) 7. In the result, appeal

Shri Samarth Sotafir Maharaj Bigar Sheti Gramin Sahakari Pat Sanstha, Teosa vs. Income Tax Officer, Ward - 5, Amravati

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

ITA 551/NAG/2025[2016-2017]Status: DisposedITAT Nagpur10 Feb 2026AY 2016-2017

Bench: Dr. Manish Borad

For Appellant: Shri Manoj G. Moryani, AdvFor Respondent: Shri Surjit Kumar Saha, Sr.DR

Section 147Section 148Section 250Section 80PSection 80P(2)(d)

vigilant and not to take 4 ITA.No.551/NAG/2025 (Shri Samarth Sotafir Maharaj Bigar Sheti Gramin Sahakari Pat Sanstha) unnecessary adjournments unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. 6 In the result, appeal of the Assessee is allowed

Late Sharad Shankar Kale, Nagpur vs. ITO Ward 5(1), Nagpur

In the result, appeal of the Assessee is partly allowed as per the terms indicated above

ITA 511/NAG/2025[2014-15]Status: DisposedITAT Nagpur10 Feb 2026AY 2014-15

Bench: Dr. Manish Borad

For Appellant: Mrs. Anchal Gupta, CAFor Respondent: Shri Surjit Kumar Saha, Sr.DR

Section 143(3)Section 250

Shankar Kale) delay. I have gone through the contents of the affidavit and the reasons stated for delay and find that the same are reasonable cause and the assessee had bonafide reason giving rise to this delay and also find that the delay is not intentional and the assessee

Gulmohar Towers Private Limited, Kolkata vs. Income Tax Officer, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 976/KOL/2025[2011-12]Status: DisposedITAT Kolkata10 Feb 2026AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S. Jhajharia, ARFor Respondent: Shri P.N. Barnwal, DR

Section 143(1)Section 147Section 148Section 148(2)

same was rejected. The Ld. D.R did raise any objection to the condoning the delay on the ground that this is not the reasonable cause for late filing of appeal. After hearing the rival contentions and perusing the materials available on record, we find that the delay is for bonafide

Jalpaiguri Zilla Regulated Market Committee, Jalpaiguri vs. Income Tax Officer, Ward 1(2), Jalpaiguri

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

ITA 2796/KOL/2025[2017-18]Status: DisposedITAT Kolkata10 Feb 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 142(1)Section 144Section 250Section 271BSection 44A

report u/s 44AB of the Act on Form-3CD was required to be filed. The Ld. AR further submitted that the assessee had a reasonable cause for not getting the audit carried out. However, no such reasonable cause was mentioned before us, except for mentioning the fact that the income ... matter may be remanded to the Ld. CIT(A) for giving another opportunity to the assessee and present its case that it had a reasonable cause for not getting the audit done, who shall decide the issue as per law. Hence, the grounds of appeal raised by the assessee

Kunkulagunta Mallikarjuna Rao, Vijayawada vs. Income Tax Officer, Ward-2(1), Vijayawada

Accordingly, finding no infirmity in the view of the CIT(A), who, in my view, in the absence of any plausible explanation of the assessee regarding the delay involved in filing of the appeal, had r...

ITA 579/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam09 Feb 2026AY 2019-20

Bench: Shri Ravish Sood, Hon’Ble

Section 144Section 147Section 148Section 148ASection 68Section 69

appellant filed against the order of the Assessing Officer by not considering the reason for delay of 210 days though the appellant has shown reasonable cause for the delay, which is due to delay in obtaining confirmation from Canara Bank regarding cash deposits. 4. The Ld. Commissioner of Income ... automatic right but requires the person requesting it to provide a valid explanation for each day of delay and demonstrate a reasonable cause. 4.5 The discretion to condone the delay has to be exercised judiciously based on facts and circumstances of each case. "Sufficient Cause" cannot be liberally interpreted

Assistant Controller F&A Directorate of Industries, Shimla vs. Income Tax Officer (TDS), Ward Shimla

ITA 98/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh09 Feb 2026AY 2017-18

Bench: the Ld. CIT(A) came to be dismissed without adjudication on merits, primarily on the ground that there was delay in filing of the appeal and that the assessee failed to respond to the notices issued by the Ld. CIT(A).

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Abhinav Bijwaria, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 194CSection 201Section 201(1)Section 271C

contumacious failure to deduct tax. In the present case, the assessee acted under a bona fide belief supported by Government practice, and there was reasonable cause within the meaning of section 273B of the Act. It was submitted that the case has not been decided ... with law. 15. It was further submitted that the penalty under section 271C was levied after due opportunity and the assessee failed to establish reasonable cause for non- deduction of tax. Hence, the orders passed by the lower authorities deserved to be upheld. 16. We have heard the rival submissions

Shree Nana Jadra Seva Sahkari Mandli Limited, Bhavnagar vs. The ITO, Ward-1(9), Bhavnagar

The appeal of the assessee is treated as allowed for statistical purposes

ITA 2570/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2570/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Shree Nana Jadra Seva Sahkari The Ito बनाम/ Mandli Ltd. Ward-1(9) V/S. At Nana Jadra Village Bhavnagar – 364 001 Mahuva Bhavnagar – 364 290 "थायी लेखा सं./Pan: Aaxas 2474 E (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Nemish Shah, Ca Revenue By : Shri Rajenkumar M. Vasavda, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 02/02/2026 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 28/10/2025 For Assessment Year (Ay) 2018-19. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal: Shree Nana Jadra Seva Sahkari Mandli Ltd. Vs. Ito Asst. Year : 2018-19

For Appellant: Shri Nemish Shah, CAFor Respondent: Shri Rajenkumar M. Vasavda, Sr.DR

Section 69A

heard on the merits of the case, which violates the principles of natural justice. 3. The appellant submits that there was sufficient and reasonable cause for the delay in filing the appeal, which was explained with necessary evidence, and the delay was not deliberate 4 The appellant prays that ... Rule 46A of the Income Tax Rules, 1962. 2. The Ld. CIT(A) failed to appreciate that the Appellant was prevented by sufficient and reasonable cause from producing the said evidence before the Assessing Officer during the assessment proceedings 3. The Ld. CIT(A) ought to have considered the additional

Walia Agni Industries Private Limited, Pune vs. ITO Ward-10(1), Pune

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

ITA 1534/PUN/2024[2014-15]Status: DisposedITAT Pune09 Feb 2026AY 2014-15

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Ninad KulkarniFor Respondent: Smt. Shraddha Nichal

Section 144Section 250Section 271(1)(c)Section 68

concealment of particulars of income as well as furnishing inaccurate particulars of income to the extent of Rs.4,70,33,658/- without any reasonable cause. During the penalty proceedings the various notices as well as the final show cause notice issued by the Ld. AO remained un-complied with

Mallikarjuna Kuntrapaka, Andhrapradesh vs. ITO, Ward- 1(3), Tirupati, Andhrapradesh

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

ITA 1899/HYD/2025[2016-17]Status: DisposedITAT Hyderabad09 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1899/Hyd/2025 Assessment Year 2016-2017 Sri Mallikarjuna Kuntrapaka, Tirupati. The Income Tax Officer, Vs. Pin – 517 501. Ward-1(3), Tirupati. Andhra Pradesh Pan Aktpk4751B (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri V Narendra Sharma, Advocate राज" व "ारा/Revenue By : Ms Payal Gupta, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 09.02.2026 घोषणा की तारीख/Pronouncement: 09.02.2026 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 31.10.2025 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The Assessment Year 2016-2017. 2

For Appellant: Sri V Narendra Sharma, AdvocateFor Respondent: MS Payal Gupta, Sr. AR

Section 144BSection 147Section 148Section 234Section 69A

further delay. 9. That there is a delay of 36 days in filing the appeal before the Hon'ble CIT(A) is due to reasonable cause and on account of circumstances beyond my control as I was drafted for election duty and could not follow up with my consultants

Income Tax Officer, Chennai vs. Railway Employees Cooperative Credit Society, Chennai

In the result, the both the appeals filed by the Revenue are dismissed

ITA 2096/CHNY/2025[2018]Status: DisposedITAT Chennai09 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. Vignesh Kumarasamy, Advocate

Section 143(3)Section 80P(2)Section 80P(2)(a)

delay, has been filed. After considering the petition filed by the Revenue and also hearing both the parties, we find that there is a reasonable cause for the Revenue in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice

Income Tax Officer, Chennai vs. Railway Employees Cooperative Credit Society Limited, Chennai

In the result, the both the appeals filed by the Revenue are dismissed

ITA 2095/CHNY/2025[2017-18]Status: DisposedITAT Chennai09 Feb 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. Vignesh Kumarasamy, Advocate

Section 143(3)Section 80P(2)Section 80P(2)(a)

Biju Pappachan, Kerala vs. AO, Bangalore

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

ITA 2153/BANG/2025[2019-20]Status: DisposedITAT Bangalore09 Feb 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2019-20

For Appellant: Ms. Akshatha Prasad, A.RFor Respondent: Sri Ganesh R Ghale, D.R

Section 250

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 ... case of CIT vs. K.S.P. Shanmugavel Nadai and Ors. (153 ITR 596) considered the condonation of delay and held that there was sufficient and reasonable cause on the part of the assessee for not filing the appeal within the period of limitation. Accordingly, the Madras High Court condoned nearly

Jamballi Shivappa, Shivamogga vs. Income Tax Officer, Ward-2, Shimoga

In the result, appeal filed by the assessee is allowed

ITA 2140/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Sri V. Narendra Sharma, A.RFor Respondent: Sri Ganesh R Ghale, A.R

Section 250Section 253(5)

assessee for not presenting the appeals within the prescribed period. The explanation therefore, becomes relevant to determine whether the same reflect sufficient and reasonable cause on the part of the assessee in not filing the appeal within the prescribed time. 6.1 While considering a similar issue the Apex Court ... 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

Anandiben Jayantilal Jain, Mumbai vs. ITO Ward 42(1)(1), Mumbai

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

ITA 8605/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailanandibenjayantilal Jain Vs. Office Of The Income Tax Officer Ward 407/B Nandavan, L.T. Road, 32(1)(1) Room No. 703, 7Th Floor, Kautilyabhavan, Boriwali(W), Mumbai-400092. Bandrakurla Complex, Bandra (East), Mumbai-400051. Pan/Gir No:Aafpj0216Q (Appellant) (Respondent)

Section 143(3)Section 250Section 69A

necessary adjudication. 5. After hearing both the parties and considering the material available on record and considering the fact that there was reasonable cause for non-attendance by the assessee before the ld CIT(A) due to health reasons and there is no findings on merits of the additions

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward-1 Palghar, Mumbai

In the result, all four appeals of the assessee stand allowed

ITA 7677/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

correspondence dated 11.08.2015 evidences that the Department had been informed about the demise of the assessee. 41. In such circumstances, there existed reasonable cause and, in any event, no contumacious conduct can be attributed so as to justify levy of penalty. Consequently, the penalty orders passed under sections 271F, 272A

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward -1 Palghar, Thane

In the result, all four appeals of the assessee stand allowed

ITA 7676/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward 1 Palghar, Thane

In the result, all four appeals of the assessee stand allowed

ITA 7675/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A