“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

Tirth Global Foundation, Chembur vs. ITO 27(3)(1) Mumbai, Vashi

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

ITA 7266/MUM/2025[AY 25-26 to AY 29-30]Status: DisposedITAT Mumbai02 Feb 2026

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar & Tirth Global Foundation V/S. Income Tax Officer–27(3)(1), 601, Glass View Society, Plot बनाम Vashi Railway Station, No. 13, Pestom Sagar, Road No. Mumbai – 400 703, 3, Opp. Shoppers Stop, Maharashtra Chembur, Mumbai – 400089, Mumbai, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadtt5346D Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Ryan Saldanha, AdvFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 12A

proviso to section 12A(1)(ac)(vi) of the Act empowers Principal Commissioner or Commissioner to condone delay if they find that there was reasonable cause in not filing application within prescribed time limit, matter was to be remanded back to Commissioner (Exemption) with a direction to treat application ... Tirth Global Foundation, Mumbai "Proviso" to Section 12A(1)(ac) that formally allows the ld.CIT(E) to condone the delay if reasonable cause is shown. We are of the considered view that the matter deserves to be restored to the file of the ld.CIT (E) for fresh consideration. The assessee

Tirth Global Foundation, Chembur vs. ITO 27(3)(1) Mumbai, Vashi

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

ITA 7265/MUM/2025[AY 2025-26 to AY 2029-30]Status: DisposedITAT Mumbai02 Feb 2026

For Appellant: Shri Ryan Saldanha, AdvFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 12A

DCIT, CC-7(2), Mumbai vs. Time Technoplast Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 6858/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Feb 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarita No.6858/Mum/2025 (A.Y. 2018-19) Deputy Commissioner Of V/S. Time Technoplast Ltd., Income Tax, Central Circle – बनाम 2Nd Floor, 55, Corporate 7(2) Avenue, Saki Vihar Road, Room No. 637, Aaykar Andheri East, Mumbai – Bhavan, M.K. Road, Mumbai 400072, Maharashtra – 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact3858L Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Rakesh Joshi,ARFor Respondent: Shri Ritesh Misra, (CIT DR)

Section 115JSection 133ASection 143(3)Section 69CSection 801CSection 80I

consideration, the deduction was disallowed on technical grounds that the assessee had not filed the return of income in time. It had provided a reasonable cause for not filing return in time. It had filed the Form 10CCB in time where the amount of deduction claimed was quantified. The delay

DCIT, CC-7(2), Mumbai vs. Time Technoplast, Mumbai

Appeal of the Revenue is dismissed

ITA 6857/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Feb 2026AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh Joshi,ARFor Respondent: Shri Ritesh Misra, (CIT DR)

Section 115JSection 133ASection 143(3)Section 69CSection 801CSection 80ISection 8o

Suresh Ratilal Lodaria, Anjar vs. Income Tax Officer Ward - 2, Gandhidham.

In the result, the appeal of the assessee is allowed

ITA 389/RJT/2025[2013-14]Status: DisposedITAT Rajkot30 Jan 2026AY 2013-14

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Vimal Desai, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(2)Section 148Section 271BSection 44A

books of accounts ready in time and hence, the audit report could not be submitted in time. Appellant submitted that there was reasonable cause for failure and that the default was only technical in nature since the A.O. had accepted the ITR in the reassessment proceedings. In VC appellant submitted ... completion of assessment proceedings on 23.03.2022. The penalty was imposed solely on the ground of non-compliance with Section 44AB without due regard to reasonable cause and in disregard of the fact that the audit report was available before the conclusion of the assessment proceedings. 9. The Ld. AR respectfully

Balvantrai Amrutbhai Vyas, Rajkot vs. The ITO Ward-2(1)(1), Rajkot.

Appeal is dismissed as “not pressed

ITA 238/RJT/2025[2011-12]Status: DisposedITAT Rajkot30 Jan 2026AY 2011-12

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Ms. Devina Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 115BSection 144Section 250Section 271(1)(c)Section 68Section 69A

appeal of the appellant in limine by falling to appreciate that the delay in filing the appeal before the Ld.CIT(A) was due to reasonable cause for which reasons were explained. 2. Order passed by the ITO, wd-2(1)(1), Rajkot u/s. 144 r.w.s

Aai Shree Khodiyar Mandir Trust Kachholi, Na vs. Arivs.Jao ITO, Exemption Ward, Surat

In the result, the appeal of the assessee is allowed

ITA 826/SRT/2025[2022-23]Status: HeardITAT Surat30 Jan 2026AY 2022-23

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Raghunath Kamble

For Appellant: Shri Sapnesh Sheth, AdvocateFor Respondent: Shri Ajay Uke, Sr. DR

Section 12ASection 143(1)Section 250

evident that the audit report was duly furnished within the prescribed time and the delay in electronic approval was purely technical and unintentional. No reasonable cause exists to deny the assessee the benefit of exemption under sections 11 and 12 of the Act. On going to the record, we find

Himakshubhai Naginbhai Chauhan, Surat vs. Income Tax Officer, Surat

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

ITA 1105/SRT/2025[2024-25]Status: HeardITAT Surat30 Jan 2026AY 2024-25

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 250

explained. In the present case, the delay has occurred due to the reason that assessee was pursuing an alternate statutory remedy, which constitutes a reasonable cause. In view of the above facts and circumstances, and considering that the appeal was dismissed without adjudication on merits, we deem it appropriate

Urban Administration Amd Development, Bhopal vs. Deputy Commissioner of Income Tax (TDS), Bhopal

In the result, the impugned order is set aside as & by way of

ITA 477/IND/2025[2015-16]Status: DisposedITAT Indore30 Jan 2026AY 2015-16

Bench: Shri B.M. Biyani & Shri Paresh M Joshidirectorate Of Urban Deputy बनाम/ Administrations & Development, Commissioner Of Vs. Nagar Palika Bhawan, 6 No.Bus Income Tax-Tds, Stop, R.S.Market, Bhopal S.O. Huzur, Bhopal(M.P.) (Tan: Bpldo1618B) (Appellant) (Respondent) Assessee By Shri Sapan Usrethe, Adv. & Ms. Apoorva Garg, Ca Revenue By Shri Anup Singh, Cit Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 30.01.2026 आदेश / O R D E R

Section 201Section 201(1)Section 246ASection 250Section 253

under:- “1.The learned Commissioner of Income tax (Appeal) was not justified in dismissing the appeal without appreciating that appellant was prevented with reasonable cause in not filing the response as appellant has not received any notices on registered postal address and thus appellant was not able to file response

District Cooperative Bank Limited, Shahjahanpur vs. Addl/Jdit (I & Ci), Lucknow

In the result, both appeals in ITA Nos

ITA 79/LKW/2025[2021-2022]Status: DisposedITAT Lucknow30 Jan 2026AY 2021-2022

For Appellant: Sh. B.P. Yadav, AdvFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR

Section 271FSection 285

information by the respective authority in a time bound manner was crucial. Since he was of the opinion that the assessee had without any reasonable cause not followed the obligations placed upon it under section 285BA(4), accordingly, he rejected the appeal of the assessee and upheld the levy ... under a bona fide belief that no return was required to be filed since there were no reportable transactions, that in itself was a reasonable cause under section 273B for not levying the penalty under section 271FA of the Act. Accordingly, it had deleted the said penalty. While doing

District Cooperative Bank Limited, Shahjahanpur, Bshahjahanpur vs. Addl / Jdit (I & Ci), Lucknow

In the result, both appeals in ITA Nos

ITA 78/LKW/2025[2019-2020]Status: DisposedITAT Lucknow30 Jan 2026AY 2019-2020

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. B.P. Yadav, AdvFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR

Section 271FSection 285

Prem Prakash Narang (HUF), Shahjahanpur vs. Income Tax Officer-1(5), Shahjahanpur

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

ITA 772/LKW/2025[2017-18]Status: DisposedITAT Lucknow30 Jan 2026AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18 Prem Prakash Narang (Huf) V. Income Tax Officer-1(5) Krishna Nagar Colony, Moh Shahjahanpur-242001. Chamkani Post Sadar, Shahjahanpur-242001. Pan:Aanhp4922P (Appellant) (Respondent) Appellant By: Shri Jitendra Kumar Yadav, Advocate Respondent By: Shri Amit Kumar, Cit(Dr) Date Of Hearing: 22 01 2026 Date Of Pronouncement: 30 01 2026 O R D E R

For Appellant: Shri Jitendra Kumar Yadav, AdvocateFor Respondent: Shri Amit Kumar, CIT(DR)

Section 115BSection 69A

accordance with law after providing due opportunity of being heard to the assessee. The assessee is directed not to seek adjournment without any reasonable cause. The grounds raised in the appeal are allowed for statistical purposes. 8. In the result, the appeal of the assessee is allowed for statistical purposes

Malika, Hardoi vs. ITO-3(2), Hardoi

In the result, the appeal of the assessee is allowed

ITA 389/LKW/2025[2019-2020]Status: DisposedITAT Lucknow30 Jan 2026AY 2019-2020

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Pranav Pandey, C.AFor Respondent: Sh. R.R.N. Shukla, Add CIT DR

Section 139(1)Section 142(1)Section 147Section 272A(1)(d)Section 56(2)(X)Section 69

Thereafter, it was the assessee’s duty to comply with the notices that had been issued. The reasons cited by her did not constitute reasonable cause under the law 2 Malika A.Y. 2019-20 therefore, there was no need to differ with the plea of the AO. He accordingly, confirmed ... provisions of various sections, no penalty shall be imposable on a person if the said person were to demonstrate that there was reasonable cause for the failure to make compliance. In the present case, we noticed that in the 3 Malika A.Y. 2019-20 statement of facts filed before

Rampal, Sitapur vs. Income Tax Officer, Sitapur

In the result, the appeal of the assessee is allowed

ITA 265/LKW/2025[2015-16]Status: DisposedITAT Lucknow30 Jan 2026AY 2015-16

Bench: SHRI KUL BHARAT (Vice President)

For Appellant: Shri Chandra Prakash Srivastava, AdvFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 142(1)Section 147Section 148Section 148ASection 149Section 3

argumentative in nature, however, the issues that clearly emerge for adjudication are that firstly, the Ld. CIT(A) failed to appreciate that there was reasonable cause for the delay in filing the appeal. The assessee being illiterate and was registered Income Tax Department Portal for the first time only

Shree Varad Vinayak Hospital and Healthcare Foundation, Pune vs. CIT(Exemption), Pune

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

ITA 2983/PUN/2025[NA]Status: DisposedITAT Pune30 Jan 2026

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

For Appellant: Shri Jasraj SutarFor Respondent: Shri Amit Bobde

Section 12ASection 80GSection 80G(5)

That the learned CIT erred in treating the time limit prescribed under section 80G as absolute, without considering that the appellant was prevented by reasonable cause in terms of section 119 2 b, as the appellant was awaiting the outcome of its 12A registration without which the 80G application could

Swapnil Suresh Mehare, Raigad vs. ITO Ward 4(5) Pune, Pune

In the result, the appeal of the assessee is partly allowed

ITA 2395/PUN/2025[2018-2019]Status: DisposedITAT Pune30 Jan 2026AY 2018-2019

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2395/Pun/2025 Assessment Year : 2018-19

For Respondent: Assessee by None

Section 142(1)Section 144Section 147Section 226Section 250Section 272A(1)(d)

compliance by way of Grounds of appeal No.2 and 3 which reads as under : “2. The appellant contends that the appellant has reasonable cause for not making any compliance during 3 Swapnil Suresh Mehare the course of re assessment proceeding considering the fact that Notices were sent on Chartered Accountant

Latthe Education Societys Employees Co Operative Credit Soc Ltd, Sangli vs. Income Tax Officer, Sangli

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

ITA 2331/PUN/2025[2020-21]Status: DisposedITAT Pune30 Jan 2026AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2331/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Latthe Education Society Vs. Assessment Unit, Employees Co-Operative Income Tax Department. Credit Soc. Ltd., Gajanan Complex, G. A. College Of Commerce, Sangli- 416416. Pan : Aaaal0118K Appellant Respondent Assessee By : None Revenue By : Shri R. Y. Balawade Date Of Hearing : 28.01.2026 Date Of Pronouncement : 30.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.09.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Of The Case & In Law The Cit(A), Nfac Erred In Confirming The Action Of The Ao Of Denying Deduction Under Section 80P In Respect Interest Earned By The Appellant Society On Deposits With Other Co-Operative Banks, Not Accepting The Submission Of The Appellant In This Respect.

For Appellant: NoneFor Respondent: Shri R. Y. Balawade

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

/NFAC appears to be genuine and therefore we are of the considered opinion that the assessee was prevented by sufficient and reasonable cause in not filing the appeal within the prescribed time limit. 8. Considering the totality of the facts of the case and in the interest of justice, without

Jitendra Nanasaheb Thorat, Nashik vs. Income Tax Officer, Ward 2(4), Nashik

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

ITA 2307/PUN/2025[2011-12]Status: DisposedITAT Pune30 Jan 2026AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2307/Pun/2025 निर्धारण वषा / Assessment Year: 2011-12 Jitendra Nanasaheb Thorat, V Income Tax Officer, A-7, Chaitrapalavi Apartment, S Ward-2(4), Nashik. Ashok Marg, Near Bank Of Maharashtra, Behind Fame Cinema, Nashik – 422006. Pan: Afypt8886Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Through Virtual) Revenue By Shri Ajitesh Kumar Meema –Addl.Cit Date Of Hearing 29/01/2026 Date Of Pronouncement 30/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2011-12 Dated 28.07.2023 Emanating From The Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Act, Dated 27.12.2017. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 68

chosen "No" for the option of receiving notices/communications over email as the appellant was not acquainted with using emails and therefore, there was a reasonable cause due to which the notices issued by the CIT(A) could not be complied by the appellant and hence, it is prayed that ... assessee are allowed for statistical purpose. Delay : 10. We have perused the Affidavit filed by Assessee. We are convinced that there was sufficient and reasonable cause for delay, hence, Delay is condoned. 11. In the result, appeal of the assessee is allowed for statistical purpose. Order pronounced in the open

Bhaskar Rajaram Thorat, Nashik vs. Income Tax Officer, Ward 2(1), Nashik

In the result, appeal of the Assessee is allowed

ITA 2301/PUN/2025[2015 - 16]Status: DisposedITAT Pune30 Jan 2026

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Chinmayy Pathak (virtual)For Respondent: Shri R.Y. Balawade, Addl.CIT

Section 142(1)Section 250Section 271(1)(b)Section 273B

assessee has not been informed about the said two notices. We find that the assessee has made out a case that there was a reasonable cause for the said failure. Under these facts and circumstances, we find that the provisions of section 273B of the Act comes to the rescue ... failure referred in the penalty provisions mentioned in section 273B of the Act, if he proves that there was a reasonable cause for the said failure. We, therefore, hold that the assessee deserves relief in the light of the provisions u/s. 273B of the Act. Accordingly, finding of the Ld.CIT

Smt. Bhagchand Gogalu Paradeshi, Jalgaon vs. ITO Ward 1(4), Jalgaon

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

ITA 2237/PUN/2025[2020-21]Status: DisposedITAT Pune30 Jan 2026AY 2020-21

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2237/Pun/2025 Assessment Year : 2020-21

For Appellant: Shri Sanket JoshiFor Respondent: Date of hearing

Section 143(3)Section 250

department for receiving the notices from ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds raised by the assessee are allowed for statistical purposes. 6. In the result, the appeal