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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

Kolhapur Zilla Krishi Karmachari Sahakari Sanstha Maryadit, Pune vs. ITO Ward 2(1), Kolhapur

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

ITA 1763/PUN/2024[2018-19]Status: DisposedITAT Pune20 Mar 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang GudhateFor Respondent: Shri Ramnath P. Murkunde
Section 143(3)Section 249Section 270ASection 80P

opportunity of hearing to the assessee. The assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause, failing which the Ld. CIT(A)/NFAC shall be free to proceed in accordance with law. The order of the Ld. CIT(A)/NFAC

Sri Sai Enterprises, Kurnool vs. Income Tax Officer, Ward-1, Kurnool

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

ITA 10/HYD/2025[2017-18]Status: DisposedITAT Hyderabad20 Mar 2025AY 2017-18

Bench: the CIT(A), the impugned order so passed by the CIT(A) was not in the knowledge of the assessee till the assessee received the copy of the said order. The Ld.AR has submitted that the assessee immediately approached another Counsel for the legal remedy against the impugned order and in that process, there is a delay in filing the present appeal. The Ld.AR has submitted that since the Counsel authorized by the assessee to represent before the CIT(A) has not responded to the notices issued by

Section 144Section 69A

protection of the properties to be sold out by the Banks for recovery of the dues and therefore, the assessee was having a reasonable cause for the delay in filing the present appeal. 3. On the other hand, the Ld. DR has opposed to the condonation of delay and submitted

M/S Manisha Rubber Enterprises, Mulund West vs. Income Tax Officer Ward 41(2)(3), Mumbai, Bandra East

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

ITA 454/MUM/2025[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सं./Ita No. 454/Mum/2025 (निर्धारण वर्ा / Assessment Year :2010-11) M/S. Manisha Rubber V/S. Ito, Ward 41(2)(3), Enterprises बिधम Mumbai 50, Unique Industrial Kautilya Bhavan, C-41 To C- Estate, Dr. R. P. Road, 43, G Block, Bandra Kurla Mulund (W), Complex, Bandra (E), Mumbai-400080 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafm6198D Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri R. R. Makwana
Section 250Section 271Section 271(1)(c)

this appeal, hence, Ld. CIT(A) dismissed the same vide order dated 21.10.2024 on the ground that the assessee could not successfully demonstrate any reasonable cause for the substantial delay. Aggrieved with the order of Ld. CIT(A), the assessee preferred an appeal before the Tribunal. 4. We have heard

Amrrut Shavjjibhai Gada, Mumbai vs. Dycit, Circle-13(2)(1), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 3773/MUM/2023[2008-09]Status: DisposedITAT Mumbai20 Mar 2025AY 2008-09

Bench: Shri. Narendra Kumar Billaiya & Shri. Sandeep Singh Karhailamrrut Shavjjibhai Gada Sejal Glass House, Krishna Kunj Ground Floor, S.V. Road, Malad West, Mumbai 400064 ……………. Appellant Pan: Aadpg5298D V/S

For Appellant: Dr. Prayag JhaFor Respondent: Shri. Ram Krishna Kedia, Sr. DR
Section 143(3)Section 221Section 221(1)Section 250

erred in not considering the fact that the assessee was facing financial difficulty during the period when the demand was payable and there was reasonable cause for failure on the part of the assessee and penalty was not leviable. 3. The Ld CIT(A), NFAC, erred in not considering

Anand Kushwaha, Bahraich vs. Income Tax Officer-1, Bahraich

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

ITA 35/LKW/2025[2018-19]Status: DisposedITAT Lucknow19 Mar 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2018-19 Anand Kushwaha V. The Ito-1 Sorrokala Bahraich Motipur Bahraich Tan/Pan:Canpk9122Q (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Manu Chaurasia, Cit(Dr) Date Of Hearing: 12 03 2025 Date Of Pronouncement: 19 03 2025 O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri Manu Chaurasia, CIT(DR)
Section 115BSection 147Section 148Section 148ASection 194HSection 282Section 69A

notice as alleged to have been issued, has been issued on wrong e-mail address, the assessee was prevented by sufficient and reasonable cause in not complying to the notices, the order passed by the CIT(A) be quashed. 03. Because the addition of Rs.1,29,72,532/- made

D.C.I.T., Range-3, Lucknow vs. Shri Manoj Gupta, Lucknow

In the result, both appeals of the department and the assessee are partly allowed

ITA 444/LKW/2020[2015-16]Status: DisposedITAT Lucknow19 Mar 2025AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudharyassessment Year: 2015-16 Manoj Gupta Acit, Range-3 V. B-1/76, Sector K, Aliganj, 27/2, P.K. Complex, Raja Lucknow-226024. Ram Mohan Rai Marg, Lucknow-226001. Pan:Aeopgg7740K (Appellant) (Respondent) Assessment Year: 2015-16 Dcit, Range-3 V. Manoj Gupta 27/2, Raja Ram Mohan Rai B-1/76, Sector K, Aliganj, Marg, P. K. Complex, Lucknow- Lucknow-226024. 226001. Pan: Aeopgg7740K (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 18.02.2025 Date Of Pronouncement: 19.03.2025 O R D E R Per Nikhil Choudhary, A.M.: Both These Appeals Arise Out Of The Order Of The Ld. Commissioner Of Income Tax Appeals-1, Lucknow [Hereinafter Referred As To “Ld. Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred As To “The Act”] Dated 18.09.2020 For The Assessment Year 2015-16. While Ita. No.355/Lkw/2020 Has Been Filed By The Assessee, Ita. No.444/Lkw/2020 Has Been Filed By The Department. As The Issues Involved In Both These Appeals Are Similar & Arise Out Of The Same Orders, The Appeals Are Taken Up For Disposal Together. The Grounds Of Appeal In Ita. No.355/Lkw/2020 Are As Under: -

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 133(6)Section 143(3)Section 145(3)Section 194CSection 250Section 68

earlier. 7. After considering the submissions of both parties, the Ld. CIT(A) admitted the additional evidences as he was satisfied that there were reasonable cause for their non-production before the Assessing Officer. He held, however, that the assessee had failed to produce the books of account during

Shri Manoj Gupta, Lucknow vs. ACIT, Range-3, Lucknow

In the result, both appeals of the department and the assessee are partly allowed

ITA 355/LKW/2020[2015-16]Status: DisposedITAT Lucknow19 Mar 2025AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudharyassessment Year: 2015-16 Manoj Gupta Acit, Range-3 V. B-1/76, Sector K, Aliganj, 27/2, P.K. Complex, Raja Lucknow-226024. Ram Mohan Rai Marg, Lucknow-226001. Pan:Aeopgg7740K (Appellant) (Respondent) Assessment Year: 2015-16 Dcit, Range-3 V. Manoj Gupta 27/2, Raja Ram Mohan Rai B-1/76, Sector K, Aliganj, Marg, P. K. Complex, Lucknow- Lucknow-226024. 226001. Pan: Aeopgg7740K (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 18.02.2025 Date Of Pronouncement: 19.03.2025 O R D E R Per Nikhil Choudhary, A.M.: Both These Appeals Arise Out Of The Order Of The Ld. Commissioner Of Income Tax Appeals-1, Lucknow [Hereinafter Referred As To “Ld. Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred As To “The Act”] Dated 18.09.2020 For The Assessment Year 2015-16. While Ita. No.355/Lkw/2020 Has Been Filed By The Assessee, Ita. No.444/Lkw/2020 Has Been Filed By The Department. As The Issues Involved In Both These Appeals Are Similar & Arise Out Of The Same Orders, The Appeals Are Taken Up For Disposal Together. The Grounds Of Appeal In Ita. No.355/Lkw/2020 Are As Under: -

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 133(6)Section 143(3)Section 145(3)Section 194CSection 250Section 68

earlier. 7. After considering the submissions of both parties, the Ld. CIT(A) admitted the additional evidences as he was satisfied that there were reasonable cause for their non-production before the Assessing Officer. He held, however, that the assessee had failed to produce the books of account during

Navchaitanya Nagari Sahakari Patsanstha Limited Atti, Satara vs. Income Tax Officer Ward 1, Satara

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

ITA 2225/PUN/2024[2021-22]Status: DisposedITAT Pune19 Mar 2025AY 2021-22

Bench: Ld. CIT(A) and to restore the issue raised on merits for necessary adjudication by Ld. CIT(A). Though Ld. DR oppose his request, we considering the facts of the case and also the contents of the application for condonation of delay filed before Ld. CIT(A), decide to condone the delay in filing of the appeal before Ld. CIT(A).

For Appellant: Shri Prateek JhaFor Respondent: Shri Manoj Tripathi
Section 143(1)(a)Section 80P

heard shall be provided to the assessee. The assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Thus, effective grounds of appeal raised by the assessee are allowed for statistical purposes. 3 4. In the result, the appeal of the assessee

The Bank of Tokyo-Mitsubishi Limited, Kolkata vs. ADIT, Int. Tax., Kolkata

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

ITA 2558/KOL/2002[1999-2000]Status: DisposedITAT Kolkata19 Mar 2025AY 1999-2000

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Sh Shyamadas Bandyopadhyay, FCAFor Respondent: Shri Bonnie Debbarma, Sr. DR
Section 36Section 37Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

Centre, Delhi confirmed the addition under section 69A and held as follows: “5.7. Even after having availed number of opportunities, the assessee without any reasonable cause failed to explain the nature & source of impugned cash deposits during assessment proceedings as well as during the appellate proceedings. Therefore there

ITO, Ward-3(1), Gaya vs. Shri Gauri Textiles Industries, Gaya

In the result, the appeal filed by the revenue is dismissed and corresponding cross-objection filed by the assessee is allowed

ITA 118/PAT/2020[2017-18]Status: DisposedITAT Patna18 Mar 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.118/Pat/2020 Assessment Year: 2017-18 Ito, Ward-3(1), Gaya…………….………………………………….…..……Appellant Vs. Shri Gauri Textile Industries, Gaya…………...........……........……...…..…..Respondent Buniadgaj Manpur, Gaya, Bihar-823003. [Pan: Aalfs4803J] C.O. No.5/Pat/2021 (Arising Out Of I.T.A. No.118/Pat/2020) Assessment Year: 2017-18 Shri Gauri Textile Industries, Gaya ……………….………………..….…..Cross-Objector Buniadgaj Manpur, Gaya, Bihar-823003. [Pan: Aalfs4803J] Vs. Ito, Ward-3(1), Gaya………….................................……........……....…..…..Respondent Appearances By: Shri Manish Rastogi, Advocate, Appeared On Behalf Of The Assessee. Shri Ashok Kumar, Cit, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : January 30, 2025 Date Of Pronouncing The Order : March 18, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal Against The Order Dated 31.08.2020 By The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As The ‘Cit(A)’] & The Assessee Has Filed The Corresponding Cross-Objection Relating To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That A Survey Was Conducted On 07.02.2017 In The Case Of The Assessee, A Partnership Firm Engaged In Trading Business Of Cotton Yarn & Hosiery Yarn. During The Survey, It Was Observed That The Assessee Has Made Substantial Deposits In Various Bank Accounts Linked With The Firm. However, The Assessee Disclosed

Section 143(2)

accordingly the C.O was filed after the delay of 34 days. We, after considering the petition filed by the assessee, find that there is reasonable cause for the delay in filing the cross-objection. Accordingly, we condone the delay. Hence, we already dismissed the appeal of the revenue, therefore

Pwd Irrigation and Lsgd Emplyees Cooperative Society Ltd No. T 638, Trivandrum vs. Income Tax Officer, Ward 2(1), Trivandrum

In the result, appeals filed by the assessee are allowed

ITA 847/COCH/2024[2017-18]Status: DisposedITAT Cochin18 Mar 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 44A

assessments, since delay in obtaining audit reports from statutory auditors under Kerala Co-operative Societies Act and Rules could be seen as a reasonable cause for delayed submission of audit reports, no penalty under section 271B was to be imposed on assessee.” 10. The facts of the case on hand

Pattom Service Co-Operative Bank Ltd No.T-1318, Thiruvananthapuram vs. DCIT, Central Circle, Thiruvananthapuram

In the result, the appeals filed by the assessee are allowed

ITA 831/COCH/2024[2016-17]Status: DisposedITAT Cochin18 Mar 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: Shri K.P. Pradeep, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 273Section 44A

appeal was filed before the CIT(A) contending that the delay in getting the accounts audited under the Co- operative Societies Act constitutes reasonable cause placing reliance on the decision of the coordinate bench of this Tribunal in the case of T.T. Kuruvilla vs. DCIT, ITA No. 504/Coch/2018 dated ... taxmann.com 45 held that the delay in obtaining the audit report under the Kerala State Co-operative Societies Act constitute reasonable cause for delay in submission of audit report us 44AB of the Act and, therefore, no penalty was leviable. 7. On the other hand, the learned Sr. DR submits

Pattom Service Co-Operative Bank Ltd No.T-1318, Thiruvananthapuram vs. DCIT, Central Circle, Thiruvananthapuram

In the result, the appeals filed by the assessee are allowed

ITA 830/COCH/2024[2015-16]Status: DisposedITAT Cochin18 Mar 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: Shri K.P. Pradeep, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 273Section 44A

appeal was filed before the CIT(A) contending that the delay in getting the accounts audited under the Co- operative Societies Act constitutes reasonable cause placing reliance on the decision of the coordinate bench of this Tribunal in the case of T.T. Kuruvilla vs. DCIT, ITA No. 504/Coch/2018 dated ... taxmann.com 45 held that the delay in obtaining the audit report under the Kerala State Co-operative Societies Act constitute reasonable cause for delay in submission of audit report us 44AB of the Act and, therefore, no penalty was leviable. 7. On the other hand, the learned Sr. DR submits

Pattom Service Co-Operative Bank Ltd No.T-1318, Thiuvananthapuram vs. DCIT, Central Circle, Thiruvananthapuram

In the result, the appeals filed by the assessee are allowed

ITA 829/COCH/2024[2014-15]Status: DisposedITAT Cochin18 Mar 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: Shri K.P. Pradeep, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 273Section 44A

appeal was filed before the CIT(A) contending that the delay in getting the accounts audited under the Co- operative Societies Act constitutes reasonable cause placing reliance on the decision of the coordinate bench of this Tribunal in the case of T.T. Kuruvilla vs. DCIT, ITA No. 504/Coch/2018 dated ... taxmann.com 45 held that the delay in obtaining the audit report under the Kerala State Co-operative Societies Act constitute reasonable cause for delay in submission of audit report us 44AB of the Act and, therefore, no penalty was leviable. 7. On the other hand, the learned Sr. DR submits

Pattom Service Co-Operative Bank Ltd No.T-1318, Thiruvananthapuram vs. DCIT, Central Circle, Thiruvananthapuram

In the result, the appeals filed by the assessee are allowed

ITA 828/COCH/2024[2013-14]Status: DisposedITAT Cochin18 Mar 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: Shri K.P. Pradeep, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 273Section 44A

appeal was filed before the CIT(A) contending that the delay in getting the accounts audited under the Co- operative Societies Act constitutes reasonable cause placing reliance on the decision of the coordinate bench of this Tribunal in the case of T.T. Kuruvilla vs. DCIT, ITA No. 504/Coch/2018 dated ... taxmann.com 45 held that the delay in obtaining the audit report under the Kerala State Co-operative Societies Act constitute reasonable cause for delay in submission of audit report us 44AB of the Act and, therefore, no penalty was leviable. 7. On the other hand, the learned Sr. DR submits

Pattom Sevice Co-Operative Bank Ltd No.T-1318, Thiruvananthapuram vs. DCIT, Central Circle, Thiruvanathapuram

In the result, the appeals filed by the assessee are allowed

ITA 827/COCH/2024[2012-13]Status: DisposedITAT Cochin18 Mar 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: Shri K.P. Pradeep, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 273Section 44A

appeal was filed before the CIT(A) contending that the delay in getting the accounts audited under the Co- operative Societies Act constitutes reasonable cause placing reliance on the decision of the coordinate bench of this Tribunal in the case of T.T. Kuruvilla vs. DCIT, ITA No. 504/Coch/2018 dated ... taxmann.com 45 held that the delay in obtaining the audit report under the Kerala State Co-operative Societies Act constitute reasonable cause for delay in submission of audit report us 44AB of the Act and, therefore, no penalty was leviable. 7. On the other hand, the learned Sr. DR submits

Pwd Irrigation Lsgd Employees Cooperative Society Ltd No T 638, Trivandrum vs. Income Tax Officer, Ward 2(1), Trivandrum

In the result, appeals filed by the assessee are allowed

ITA 824/COCH/2024[2016-17]Status: DisposedITAT Cochin18 Mar 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Keshav Dubey, Jm

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 271BSection 44A

assessments, since delay in obtaining audit reports from statutory auditors under Kerala Co-operative Societies Act and Rules could be seen as a reasonable cause for delayed submission of audit reports, no penalty under section 271B was to be imposed on assessee.” 10. The facts of the case on hand

Ashok Kumar Jain, Kota vs. ITO WD-2(1), Kota

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

ITA 1225/JPR/2024[2015-16]Status: DisposedITAT Jaipur18 Mar 2025AY 2015-16
For Appellant: Sh. Mahendra Gargieya, Adv.& Sh. Devang Gargieya, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 147Section 250Section 253(3)Section 5

on/before dated 29.09.2024 however, the same has been filed on dated 01.10.2024. Thus, the appeal was filed with a delay of 2 days. 2. Reasonable Cause Exist: In this connection, it is humbly submitted that although there was no delay in filing the instant appeal, in as much

Syaani Legal Heir Late Narayan Jat, Jaipur vs. ITO Ward 7(2), Jaipur

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

ITA 1119/JPR/2024[2010-11]Status: DisposedITAT Jaipur18 Mar 2025AY 2010-11

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

For Appellant: Shri R.S. Poonia, C.AFor Respondent: Mrs. Swapnil Parihar, JCIT-DR a
Section 54

appeal before CIT(Appeals) was due to death of my Husband Narayan Jat and I was unware and same can be treated as reasonable cause and bonafide.” To this effect, the assessee has filed an affidavit as to the condonation of delay in filing the appeal. 2.2. During the course

Sant Shiromani Swami Lilashah Trust, Banaskantha vs. The CIT(Exemption), Ahmedabad

The appeals of the assessee are allowed for statistical purposes

ITA 64/AHD/2025[NA]Status: DisposedITAT Ahmedabad18 Mar 2025

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.63/Ahd/2025 & 64/Ahd/2025 िनधा"रण वष" /Assessment Year : - Sant Shiromani Swami The Cit (Exemption) बनाम/ Lilashah Trust Ahmedabad – 380 015 V/S. Deesa, Disa Bazar S.O. Deesa Banaskantha – 385 535 "थायी लेखा सं./Pan: Abcts 9755 P अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Ms. Urjita Shah, Ca Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 18 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Are Two Separate Appeals Filed By The Assessee Relating To Registration Under Section 12A(1)(Ac)(Iii) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) & Approval Under Section 80G(5) Of The Act. Since Both The Appeals Involve Common Facts & Issues, For The Sake Of Convenience, They Are Disposed Of By This Common Order.

For Appellant: Ms. Urjita Shah, CAFor Respondent: Shri R.N. Dsouza, CIT-DR
Section 12(1)Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80G(5)

hearing before us, the Authorized Representative (AR) of the assessee requested condonation of delay of 8 days in filing the appeal(s), citing reasonable causes mentioned in the affidavits. The AR submitted that part details were submitted before CIT(E), but the audited financial statements could not be submitted