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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

Sri Rameshwara Bahu Uddeshi Souharda Sahakari Sangha Niyamitha, Shimoga vs. Income Tax Officer, Ward-5, Shimoga

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

ITA 1703/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Jan 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Smt. Pratibha R, Advocate
Section 2(19)Section 80PSection 80P(2)(a)

condoning the delay of 17 days in filing the appeal, the CIT(A) ought to have 5. further appreciated that there was a ----------- reasonable cause to condone the delay. Thus, the matter has to be heard on merits On the facts, the learned assessing officer ought to have accepted

Bihar Medical Services and Infrastructure Corporation Limited, Patna vs. DCIT, Circle-1, Patna

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

ITA 363/PAT/2023[2013-14]Status: DisposedITAT Patna06 Jan 2025AY 2013-14

Bench: the Assessing Officer to the notices issued by him. It is seen that even before the Ld. CIT(A), the assessee did not make any worthwhile presentation except that written submissions were filed in which it was mentioned that compliance could not be made before the Ld. Assessing Officer because a number of staff were suffering from COVID and hence were not alert enough to make proper representation before the Revenue Authorities. However, going by the fact that even before the Ld. CIT(A) ther

Section 147Section 151Section 250Section 271

Services and Infrastructure Corporation Limited 7. For that the Ld. CIT(A) has failed to appreciate that the appellant was prevented by sufficient and reasonable cause in making compliance to notices u/s 142(1) during re-assessment proceedings. 8. For that the Ld. CIT(A) has erred in confirming penalty

Bihar Medical Services and Infrastructure Corporation Limited, Patna vs. DCIT, Circle-1, Patna

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

ITA 362/PAT/2023[2013-14]Status: DisposedITAT Patna06 Jan 2025AY 2013-14

Bench: the Assessing Officer to the notices issued by him. It is seen that even before the Ld. CIT(A), the assessee did not make any worthwhile presentation except that written submissions were filed in which it was mentioned that compliance could not be made before the Ld. Assessing Officer because a number of staff were suffering from COVID and hence were not alert enough to make proper representation before the Revenue Authorities. However, going by the fact that even before the Ld. CIT(A) ther

Section 147Section 151Section 250Section 271

Services and Infrastructure Corporation Limited 7. For that the Ld. CIT(A) has failed to appreciate that the appellant was prevented by sufficient and reasonable cause in making compliance to notices u/s 142(1) during re-assessment proceedings. 8. For that the Ld. CIT(A) has erred in confirming penalty

Anil Singh Hariprasad Singh Rajput, Surat vs. ITO, Ward-3(2)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 859/SRT/2024[2017-18]Status: DisposedITAT Surat03 Jan 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 859/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Anil Singh Hariprasad Singh Income Tax Officer, Ward- Rajput,135-135, Viththal Nagar 3(2)(1), Surat, Room No.416, बनाम Society, Bapasitram Chowk, Dabholi 4Th Floor, Aaykar Bhawan, Vs Road, Surat-395 004 Majura Gate, Opp. New Civil [Pan : Amnpr 5655 F] Hospital, Surat-395 001 अपीलाथ"/Appellant ""थ" /Respondent

Section 115BSection 144Section 15BSection 234ASection 254(1)Section 271ASection 271FSection 272A(1)(d)Section 69A

dismissed appeal as unadmitted. Resultantly, the addition made by Assessing Officer was confirmed. The Ld. AR of the assessee submits that there was reasonable cause for condonation of delay. In fact, the assessment was completed under section 144. The consultant of the assessee has mentioned his mobile and e-mail

Meenakshi Yadav, Ahmedabad vs. The Income Tax Officer, Ward-4(1)(1), Ahmedabad

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

ITA 1558/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Jan 2025AY 2018-19

Bench: Dr.Brr Kumarshri Siddhartha Nautiyal

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri BP Srivastava, Sr. DR
Section 144

portal. However, having known about the passing of order, the assessee had filed appeal before the Ld.CIT(A). We find that the assessee had reasonable cause and delay of 17 days shall not prejudice the rights of the assessee to redress her grievances before the first appellate authority. Further

Pudumjee Paper Products Limited, Pune vs. ACIT Circle 8 Pune, Pune

In the result, appeal of the assessee is allowed

ITA 2079/PUN/2024[2018-19]Status: DisposedITAT Pune03 Jan 2025AY 2018-19

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Arvind Desai
Section 115JSection 143(1)Section 249Section 250

delay was during the Covid period and has to be excluded in view of decision of Hon’ble Supreme Court and there was a reasonable cause for the balance delay. He accordingly submitted that the matter may be restored to the file of Addl./JCIT(A) with a direction ... dated 22.11.2019, therefore, when the assessee filed an appeal before the Addl./JCIT(A), he should have condoned the delay since there was a reasonable cause for not 8 ITA.No.2079/PUN./2024 filing the appeal in time. We, therefore, set aside the order of the Addl./JCIT(A) and restore

Modesty Garments, New Delhi vs. JCIT, Range-28(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2574/DEL/2022[2016-17]Status: DisposedITAT Delhi03 Jan 2025AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us[Assessment Year : 2016-17] Modesty Garments Vs Jcit B-304, New Friends Colony Range-28(1) New Delhi-110025. New Delhi Pan-Aaafm1598F Appellant Respondent Appellant By Shri Mohit Gupta, Ca Shri Nitin Sharma, Ca & Shri Neeraj Singh, Ca Respondent By Shri Anshul, Sr. Dr Date Of Hearing 07.10.2024 Date Of Pronouncement 03.01.2025

Section 250Section 269T

which stipulates that penalty under s. 271E is not to be imposed on a person for any failure, if he proves that there was reasonable cause for such failure in accepting/repaying the loan/deposits in modes other than the ones prescribed. The journal entries in the instant case appear to have

Padma Rao Thigulla, Hyderabad vs. ITO., Ward 10(4), It Towers, Hyderabad

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

ITA 1160/HYD/2024[2017-18]Status: DisposedITAT Hyderabad03 Jan 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1160/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2025-26) Telugu Neravu Vs. Income Tax Officer Srikalahasti Ward -1 Pan:Aaett4108J Chittoor (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Ram Prasad, Ca राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 10/09/2025 घोषणा की तारीख/Pronouncement: 17/09/2025 आदेश/Order

For Appellant: Shri T. Ram Prasad, CAFor Respondent: : Dr. Narendra Kumar Naik, CIT(DR)
Section 12A

assessee be admitted for adjudication. 3. On the other hand, the learned DR has submitted that the assessee has not explained any reasonable cause for the delay in filing the appeal. 4. We have considered the rival contentions as well as the relevant material available on record. The assessee ... fair account of the circumstances which has caused the delay in filing the appeal, we are satisfied that the assessee was having a reasonable cause for the delay in filing the appeal. Accordingly, the delay of 45 days in filing the appeal is condoned. 5. The assessee has filed

Dr. Murugesh Shantveerya Hiremath, Pune vs. DCIT, Central Circle 1(5), Pune

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

ITA 1558/PUN/2024[2018-19]Status: DisposedITAT Pune02 Jan 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1558/Pun/2024 िनधा"रण वष" / Assessment Year : 2018-19 Dr. Murugesh Shantveerya Vs. Dcit, Central Circle-1(5), Hiremath, Pune. 1126/B, Model Colony Road, Shivajinagar, Pune- 411016. Pan : Aadph0605H Appellant Respondent Assessee By : Shri M. R. Bhagwat Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 18.11.2024 Date Of Pronouncement : 02.01.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.06.2024 Passed By Ld. Cit(A)-11, Pune [‘Cit(A)’] For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1) The Learned Cita Nfac Erred In Confirming The Levy Of Penalty Under Section 271B Of The Income Tax Act Even Though The Tax Payer Had A Reasonable Cause For Not Getting His Accounts Audited For The Relevant Previous Year. 2) The Penalty Of Rs. 1,50,000/- Imposed Under Section 271B Be Cancelled. 3) Such Other Orders Be Passed As Deemed Fit & Proper.

For Appellant: Shri M. R. BhagwatFor Respondent: Shri Ramnath P. Murkunde
Section 133ASection 139(1)Section 271BSection 44A

CITA NFAC erred in confirming the levy of penalty under section 271B of the Income Tax Act even though the tax payer had a reasonable cause for not getting his accounts audited for the relevant previous year. 2) The penalty of Rs. 1,50,000/- imposed under section 271B ... observing that the assessee has committed default in obtaining & e-filing of the Audit Report before the prescribed due date, without having any reasonable cause. 3 4. Being unsatisfied with the reply of the assessee, Ld. CIT(A) dismissed the appeal of the assessee & confirmed the penalty u/s 271B

Asst Commissioner of Income Tax CC 1 4 Mumbai, Mumbai vs. Jatin Rajnikant Shah, Mumbai

ITA 4468/MUM/2024[2017]Status: HeardITAT Mumbai02 Jan 2025

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 10Section 11Section 12Section 12ASection 80GSection 80G(5)(iii)Section 80G(5)(iv)

said application was also rejected by the CIT(E) stating that the assessee has not shown a reasonable cause for delay in filing the application and the CIT(E) did not condone the delay. Further the CIT(E) also held that the assessee has not offered any comments on violation ... Accordingly we are unable to agree with the finding of the CIT(E) that the rejection of first application is not a reasonable cause for the delay in filing the second application and the delay is thus condoned. As already stated the CIT(E) did not examine the application

M/S. Subhrashi Enclave Pvt. Ltd., Kolkata vs. ITO, 10 (2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1963/KOL/2024[2015-16]Status: DisposedITAT Kolkata02 Jan 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1963/Kol/2024 Assessment Year: 2015-16 M/S Subhrashi Enclave Pvt. Ltd...…..…………………....Appellant 14-C, M.D. Road, 4Th Floor, Kolkata – 700007. [Pan: Aascs6378Q] Vs. Ito, Ward-10(2), Kolkata…. ….…….…............................…..…..... Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri S.B. Chakraborthy, Addl. Cit & Somnath Das & Somnath Das Biswas, Sr. Drs, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2024 Date Of Pronouncing The Order : January 02, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 01.09.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Appeal Is Time-Barred By 324 Days. An Application For Condonation Of Delay Has Been Filed, Which Is Also Supported With The Affidavit Of Shri Subhash Sharma, The Director Of The Assessee Company, Wherein, It Has Been Pleaded That The Impugned Order Of The Cit(A) Was Passed On 01.09.2023 But The Order Was Communicated To The Assessee On 03.09.2024. Immediately, The Assessee Engaged An Authorized Representative & Filed The Appeal. The Ld. Ar Further Stated That The Notice & Also The Impugned Order Were Not Duly Served Upon The Assessee Due To Mismatch Of Email Address Which Was Provided In Form 35. Therefore, The Assessee Was Not Aware Of The Passing Of The

Section 143(2)Section 250

circumstances and the assessee is not a wilful defaulter. Therefore, the ld. AR prayed for condonation of delay. Considering the above submissions, we find reasonable cause behind such delay. Accordingly, we condone the delay of 324 days in filing of the present appeal and proceed to decide the appeal

Pawan Kumar, Prop. Life Line Rice Mills, Begusarai vs. ACIT, Circle-2(1), Begusarai

In the result, these two appeals filed by the assessee are allowed for

ITA 15/PAT/2022[2013-14]Status: DisposedITAT Patna01 Jan 2025AY 2013-14
Section 144Section 145Section 148Section 250

appellant states that the same does occurred due to reasons beyond its control. The appellant submits that the same is due to a reasonable cause. 6. The appellant submits that since the delay was caused due to a reasonable cause the same merit not be condoned. The appellant submits that

Pawan Kumar, Prop. Life Line Rice Mills, Begusarai vs. ACIT, Circle-2(1), Begusarai

In the result, these two appeals filed by the assessee are allowed for

ITA 14/PAT/2022[2012-13]Status: DisposedITAT Patna01 Jan 2025AY 2012-13
Section 144Section 145Section 148Section 250

appellant states that the same does occurred due to reasons beyond its control. The appellant submits that the same is due to a reasonable cause. 6. The appellant submits that since the delay was caused due to a reasonable cause the same merit not be condoned. The appellant submits that

Y.G. Capital Ltd., Mumbai vs. Deputy Commissioner of Income Tax, Circle-7, Kolkata

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

ITA 1095/KOL/2024[2010-11]Status: DisposedITAT Kolkata01 Jan 2025AY 2010-11

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(3)Section 14ASection 250

aforesaid appeal. 1.2. Considering the condonation application and the reasons stated therein, we are satisfied that the assessee was prevented by sufficient and reasonable cause from filing the instant appeal within the statutory time limit. We, therefore, condone the delay and admit the appeal for adjudication on merits

Manjari Housing Projects LLP, Maharashtra vs. The Deputy Director of Income Tax, Centralized Processing Centre, Bengaluru, Bandra Kurla Complex, Mumbai

Accordingly, we set aside the impugned order passed by the learned CIT(A) for the assessment year 2018-19. As a result, grounds raised by the assessee are allowed

ITA 3368/MUM/2024[2021-22]Status: DisposedITAT Mumbai01 Jan 2025AY 2021-22

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

For Respondent: Shri Rajesh Sakhardande, SR-DR
Section 143(1)Section 2(19)Section 250Section 80PSection 80P(1)Section 80P(2)(d)

addition made by CPC should be deleted. 4. The ld. DR on the other hand submitted that the assessee has not submitted the reasonable cause for delay in filing the appeal before the FAA and the FAA has rightly dismissed the appeal in limine. KCA Cooperative Credit Society

M/S Gujarat Enterprises, Mumbai Suburban vs. Income Tax Officer-32(1)(5), Mumbai

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

ITA 4203/MUM/2023[2007-08]Status: DisposedITAT Mumbai01 Jan 2025AY 2007-08

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawalchandarkishore Vs. Ito, Ward 42(2)(1) Nandkishore Seksaria Kautilya Bhawan, Bkc 70, Seksaria House, Jb Bandra (E) – 400 051. Nagar, Andheri (E), Mumbai – 400 059. Pan/Gir No. Amxps4815N (Applicant) (Respondent)

Section 142(1)Section 144Section 148Section 250Section 270A

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

Mohd Vizzarath Ali, Hyderabad vs. Income Tax Officer, Ward-8(2), Hyderabad

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

ITA 1271/HYD/2024[2017-18]Status: DisposedITAT Hyderabad01 Jan 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1271/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18) Mohd.Vizzarath Ali Vs. Ito, Ward-8(2) Hyderabad Hyderabad [Pan : Avdpa3594K] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms.S.Sandhya, Ar रधजस् व द्वधरध/Revenue By:: Ms.P.Sunitha, Dr सुिवधई की तधरीख/Date Of Hearing: 01/01/2025 घोर्णध की तधरीख/Date Of 01/01/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.08.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2017-18. 2. At The Outset, It Is Observed That The Appeal Has Been Filed With A Delay Of 47 Days. The Assessee Filed An Affidavit For Condonation Of Delay & Submitted That The Assessee Was Under Medical Treatment For B/L Renal Calculi & Lumbar Spondalysis & He Was Advised Complete Bedrest. The Assessee

For Appellant: Ms.S.Sandhya, ARFor Respondent: : Ms.P.Sunitha, DR
Section 115BSection 139Section 142(1)Section 144Section 69A

before 31.10.2024, but the assessee filed appeal on 06.12.2024, with the delay of 36 days. We find that there is a reasonable cause for the assessee to file the appeal belatedly, hence, we condone the delay of 36 days in filing of the appeal before the Tribunal and admit

Sanjeevkumar Jayantilal Shah, Idar vs. The Jt.CIT., Himatnagar Range, Himatnagar

In the result, appeal filed by the assessee is allowed

ITA 1073/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad01 Jan 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2014-15

Section 143(3)Section 269TSection 271ESection 273BSection 274

following grounds of appeal :- “1. Assessing Officer erred in levying penalty under section 271E for repayment of INR 22,90,148/- since there was reasonable cause for making such payment. During the year, INR 47,36,724/- (59,81,866- 12,45,142(Table B) have been paid through ECS/Cheques ... rightly imposed the penalty as the claim made by the assessee for making substantial repayment in cash on difference occasions does not constitute reasonable cause under Section 273B of the Act. 7. We have heard the Ld. DR and perused all the relevant material available on record. It is pertinent

Satwik Feeds, New Delhi vs. Deputy Commissioner of Income Tax, Circle - 35(1), Delhi

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

ITA 1064/DEL/2024[2017-18]Status: DisposedITAT Delhi01 Jan 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 132(4)Section 153A

imposed u/s 271B of the act deserves to be deleted being the delay was not intentional but the appellant was prevented by reasonable cause for filing of tax audit report within stipulated time limit. That the appellant craves leave to add, alter, delete & modify any of the ground of appeal ... audited within the stipulated period and therefore the provision for Section 271B were clearly applicable in this case. The appellant could not provide any reasonable cause of failure which had prohibited him to get his books of account audited within the stipulated time. Therefore in my considered opinion this

Ektalis Gam Patidar Development Foundation, Gandhinagar vs. The ITO, Ward-1(Exemption), Ahmedabad

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

ITA 1867/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad31 Dec 2024AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T.R. Senthil Kumar (Judicial Member)

Section 115BSection 12ASection 142(1)Section 143(1)Section 148Section 272A(1)(d)Section 273B

which has resulted in passing an exparte assessment order. Therefore assessee requested not to levy penalty u/s. 273B of the Act, as reasonable cause for the failure on the part of the assessee to reply to the notice. The above explanation was rejected I.T.A No. 1867/Ahd/2024 A.Y. 2017-18 Page ... order, assessee filed an appeal which is pending before Ld. CIT(A). As against the levy of penalty, the assessee has brought out a reasonable cause for not complying with the notice issued u/s. 142(1) of the Act. Therefore invoking u/s. 273B, no penalty shall be imposed