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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

Rajiv Pandurang Lembhe, Aurangabad vs. ITO, Ward-1(5), Aurangabda, Aurangabad

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

ITA 1952/PUN/2025[2021-22]Status: DisposedITAT Pune28 Jan 2026AY 2021-22

Bench: Dr. Manish Borad

For Appellant: Shri Ramesh Thete PatilFor Respondent: Shri Vishwajit Shinde, JCIT
Section 139Section 143(1)Section 143(1)(a)Section 250

Ld.JAO shall grant fair hearing of opportunity to the assessee before framing assessment and the assessee shall not take unnecessary adjournments unless required for reasonable cause. Effective grounds raised by the assessee are allowed for statistical purposes. 7. In the result, appeal of the Assessee is allowed for statistical purposes

Junnar Taluka Prathamik Shikshak Sahakari Pathsantha, Pune vs. Pne-W-59(1), Pune

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

ITA 1659/PUN/2025[2021-22]Status: DisposedITAT Pune28 Jan 2026AY 2021-22

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No.1659/Pun/2025 धििाारण वर्ा /Assessment Year: 2021-22 Junnar Taluka Prathamik Pne-W-59(1), Pune Shikshak Sahakari Patsanstha, Junner, Vs. Junnar-410502 Pune Maharashtra Pan-Aaaaj3324K अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: None Department By: Shri R.Y. Balawade, Addl. Cit Date Of Hearing: 28-01-2026 Date Of Pronouncement: 02-02-2026 आदेश / Order Per Dr. Manish Borad:- This Appeal At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A) Nfac, Delhi Framed U/S 250 Of The Act, Dated 10.03.2025 For A.Y. 2021-22 Which Is Arising Out Of Assessment Order U/S 143(3) R.W.S. 144B Of The Act Dated 05.12.2022. 2. Registry Has Informed That There Is Delay Of 45 Days In Filing Of The Present Appeal. Application For Condonation Of Delay Alongwith Affidavit Is Placed On Record & On Going Through The Same, We Find That The Delay Is Not Intentional. Therefore In The Larger Interest Of Justice & Placing Reliance

For Appellant: NoneFor Respondent: Shri R.Y. Balawade, Addl. CIT
Section 143(3)Section 250Section 250(6)Section 80PSection 80P(2)(d)

latest e-mail id and mobile No. on the website and also remain vigilant and not to take adjournment 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 for statistical

Renuka Silver Merchents, Nizamabad vs. Income Tax Office, Ward-1, Nizamabad

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

ITA 972/HYD/2025[2017-18]Status: DisposedITAT Hyderabad28 Jan 2026AY 2017-18

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 142(1)Section 143(2)

affidavit filed by the assessee seeking condonation of delay in filing the appeal. We find that, the reasons explained by the assessee constitute ‘reasonable cause’. The Hon’ble Supreme Court in the case of Collector, Land Acquisition Vs. MST. Katiji [1987] 167 ITR 471 (SC) has held that, a liberal

Babugari Kareem Basha, Kurnool vs. Income Tax Officer, Ward-1, Nandyal

In the result, appeals of the Assessee are dismissed mutatis mutandis for both the A

ITA 1449/HYD/2025[2017-18]Status: DisposedITAT Hyderabad28 Jan 2026AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 147Section 249(3)Section 69A

importance of limitation provided under various statutes and the discretionary power conferred by the said statute keeping in mind the phrase ‘sufficient and reasonable cause’. This view is further exhilarated by the decision of Hon’ble Supreme Court in the case of M/s. Kolte Patil Developer

Babugari Kareem Basha, Kurnool vs. Income Tax Officer, Ward-1, Nandyal

ITA 1448/HYD/2025[2014-15]Status: DisposedITAT Hyderabad28 Jan 2026AY 2014-15
Section 147Section 249(3)Section 69A

importance of limitation provided under various statutes and the discretionary power conferred by the said statute keeping in mind the phrase 'sufficient and reasonable cause”. This view is further exhilarated by the decision of Hon'ble Supreme Court in the case of M/s. Kolte Patil Developer

Bscpl Aurang Tollway Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 612/HYD/2024[2018-19]Status: DisposedITAT Hyderabad28 Jan 2026AY 2018-19

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within 60 days from the date of receipt of the order passed under Section 263 of the Income-tax Act, 1961. However, the

Section 143(3)Section 263

Revenue, Dr. Narendra Kumar Naik, on the other hand, did not oppose the request for condonation of delay, in view of the reasonable cause explained by the assessee. 5. We have heard both parties and perused the petition and affidavit filed by the assessee, seeking condonation of delay in filing ... appeal. We find that, the reasons explained by the assessee constitute reasonable cause. The Hon'ble Supreme Court in the case of Collector, Land Acquisition Vs. MST. Katiji [1987] 167 ITR 471 (SC) has laid down that a liberal and pragmatic approach should be adopted while considering applications

Subramaniam Suresh, Namakkal vs. ITO, Ward 1(6), Salem

ITA 3347/CHNY/2025[2012-13]Status: DisposedITAT Chennai28 Jan 2026AY 2012-13

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3346 & 3347/Chny/2025 िनधा$रण वष$ /Assessment Years: 2012-13

For Appellant: Mr. T.S.Lakshmi Venkatraman, FCAFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

during the Covid period and considering the submissions made by the assessee in the affidavit, we are convinced that there is a reasonable cause for the delay in filing the appeal before the CIT(A) also. Taking into account the facts and circumstances peculiar to the present case

Subramaniam Suresh, Namakkal vs. ITO Ward 1(6), Salem

ITA 3346/CHNY/2025[2012-13]Status: DisposedITAT Chennai28 Jan 2026AY 2012-13

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3346 & 3347/Chny/2025 िनधा$रण वष$ /Assessment Years: 2012-13

For Appellant: Mr. T.S.Lakshmi Venkatraman, FCAFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

during the Covid period and considering the submissions made by the assessee in the affidavit, we are convinced that there is a reasonable cause for the delay in filing the appeal before the CIT(A) also. Taking into account the facts and circumstances peculiar to the present case

Premji Bhurlal Gala, Mumbai vs. Addl CIT Rang 24(1), Mumbai

In the result, Assessee’s appeal is allowed

ITA 6596/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Jan 2026AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2016-17 Premji Bhurlal Gala Addl. Cit Range 24(1), B-301, Water Ford, Cd Mumbai Barfiwala Road Juhu Fally Kautilya Bhavan, C-41 To C- Vs. Andheri West, Mumbai - 43, G Block, Bandra Kurla 400058 Complex, Bandra (E) Mumbai – 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Vinod Kumar Bindal & Satish Kumar, Ld. A. Rs. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 09.12.2025 Date Of Pronouncement : 28.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 23.09.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In The Instant Case, The Case Of The Assessee Was Reopened Under Section 147 Of The Act, On The Basis Of Search & Survey Action Under Section 132 Of The Act Carried Out In The Case Of M/S. Evergreen Enterprises, Wherein The Statement Of The Partner In M/S. Evergreen Enterprises, Mr. Nilesh Bharani Was Recorded Under Section 132(4) Of The Act, Unearthing An Undisclosed Activity, 2 Premji Bhurlal Gala

For Appellant: Shri Vinod Kumar Bindal & SatishFor Respondent: Shri Virabhadra Mahajan, SR. D.R
Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 269SSection 271Section 271D

himself. Hence, the appellant cannot now claim denial of opportunity when he failed to respond within the time provided during the assessment proceedings. iv. Reasonable Cause under Section 2738: The appellant has not provided any cogent evidence or explanation showing reasonable cause for the acceptance of 6 Premji Bhurlal Gala ... loan, even assuming such a loan was taken. Mere denial of transaction or pendency of quantum appeal does not constitute reasonable cause under Section 273B. v. Penalty Proceedings Independent of Assessment:- It is well settled in law that penalty u/s 271D is independent of the outcome of the quantum assessment

Kartavyam, Kripal Apartment Ip Extension vs. CIT(Exemption), Civic Centre, Minto Road

In the result, both the appeals filed by the assessee stand allowed for

ITA 6400/DEL/2025[2026-27]Status: DisposedITAT Delhi28 Jan 2026AY 2026-27

Bench: Shri Sudhir Kumar & Smt. Renu Jauhri

For Appellant: Sh. Dipak Mandal, CAFor Respondent: Sh. Jitender Singh, CIT(DR)
Section 12ASection 12A(1)(ac)Section 80G

this purpose, the assessee has filed the condonation petitions alongwith supporting affidavits. After hearing both the sides and perusing the records, we find that reasonable cause has been attributed to the applicant-assessee in filing the belated appeals before the Tribunal, hence, we condone the delay in dispute in both

Kartavyam, Delhi vs. CIT(Exemption), Civic Centre New Delhi

In the result, both the appeals filed by the assessee stand allowed for

ITA 6399/DEL/2025[2026-27]Status: DisposedITAT Delhi28 Jan 2026AY 2026-27

Bench: Shri Sudhir Kumar & Smt. Renu Jauhri & A.Yr. : 2026-27 Kartavyam, Vs. Commisisoner Of Income 52, Kripal Apartment I.P. Tax (Exemption), Delhi Extension, Patparganj, Civic Centre, Minto Road, Delhi – 110 092 New Delhi – 110 002 (Pan: Aactk6151A) (Appellant) (Respondent)

For Appellant: Sh. Dipak Mandal, CAFor Respondent: Sh. Jitender Singh, CIT(DR)
Section 12ASection 12A(1)(ac)Section 80G

this purpose, the assessee has filed the condonation petitions alongwith supporting affidavits. After hearing both the sides and perusing the records, we find that reasonable cause has been attributed to the applicant-assessee in filing the belated appeals before the Tribunal, hence, we condone the delay in dispute in both

ACIT, Circle-52(1), New Delhi, Delhi vs. Singhania Alu Foil Containers Manufacturing Company, New Delhi

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

ITA 2743/DEL/2024[2015-16]Status: DisposedITAT Delhi28 Jan 2026AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Manish Gupta, Sr.DR
Section 143(2)Section 143(3)Section 68

appeal be condoned. We have heard both the counsels on the issue of condonation of delay. In our considered opinion, there was a reasonable cause for the delay in filing the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal. Brief facts of the case

Mr. Sinnappa Vanku Waghmode, Vatpali vs. ITO Ward 2, Pandharpur

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

ITA 2805/PUN/2025[2015-16]Status: DisposedITAT Pune27 Jan 2026AY 2015-16

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.2805/Pun/2025 Assessment Year : 2015-16

For Appellant: Shri Aakash Parakh and Shri Piyush Bafna
Section 147Section 148Section 250Section 250(6)Section 56Section 69

Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987) 2 SCC 107) we find that due to ‘reasonable cause’ assessee failed to file the appeal within the time limit specified under the Act. We therefore condone the delay of 178 days in filing the appeal ... 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. 4 Sinnappa Vanku Waghmode

Kolhar Bhagwatipur Vapari Gramin Bigarsethi Sahakari Patsanstha Ltd, Ahilyanagar vs. ITO, Ward-1, Ahilyanagar

In the result, both the appeals filed by the Assessee are allowed for statistical purposes

ITA 1877/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

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

For Appellant: Shri Prasad BhadariFor Respondent: Shri Vidya Ratna Kishore
Section 148

Sagar Sable on 03/05/2021 due to Covid-19 pandemic who was looking after the taxation work of the assessee. We find that reasonable cause which prevented the assessee from filing the appeals before the Ld.CIT(A) within the prescribed time limit and delay is not intentional and therefore adopting ... 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. 8. In the result, both the appeals filed by the Assessee

Jaya Chandra Rajan, Tirunelveli vs. ITO, Ward 1 Tirunelvel, Tirunelvel

ITA 3329/CHNY/2025[2015-16]Status: DisposedITAT Chennai27 Jan 2026AY 2015-16
Section 144BSection 147Section 148

Manivasagam, Addl. CIT 20.01.2026 27.01.2026 2. We condone the delay of 292 days in filing appeal before the Tribunal which is based upon the reasonable cause (Medical Certificate attached) and admit the same for adjudication. 2.1 At the outset, Id.AR for the assessee pointed out G.No.2 which states that

Shaivam Org Trust, Trichy vs. CIT, Exemptions, Chennai

ITA 3153/CHNY/2025[-]Status: DisposedITAT Chennai27 Jan 2026

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3153/Chny/2025

For Appellant: Mr. Velpandiar, AdvocateFor Respondent: Mr. A. Sasi Kumar, CIT
Section 12ASection 12A(1)(ac)

under the appropriate clause; however, the application came to be rejected on technical grounds. Therefore, we find merit in the submission that there existed reasonable cause for the delay in filing the second application by the assessee. Considering the facts peculiar to the present case and in the interest

Surinder Kumar Malhotra, Delhi vs. National Faceless Assessment Center, Delhi

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

ITA 6370/DEL/2025[2018-19]Status: DisposedITAT Delhi27 Jan 2026AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Sh. Sombir Singh, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 234ASection 250Section 68

Surinder Kumar Malhotra explained, we are of the view that the delay was on account of reasonable cause and hence, the same is hereby condoned. 3. The assessee has raised the following grounds of appeal: “1. That under the facts and circumstances of the case, the impugned order dated

Priti Bhansali, Bharuch vs. ITO, Ward 1, Bharuch

In the result, the appeal of the assessee is allowed and the penalty levied is deleted

ITA 1023/SRT/2025[2018-19]Status: HeardITAT Surat23 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblepriti Bhansali, Income Tax Officer, Vs. D 1, Rajashree Nagar, Ward-1, Umalla, Bharuch. Bharuch-39310. [Pan : Agspb2559 H] (Appellant) .. (Respondent) Appellant By : Shri Pradeep Kumar Jain, Ar Respondent By: Shri Ajay Uke, Sr. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 23.01.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Pradeep Kumar Jain, ARFor Respondent: Shri Ajay Uke, Sr. DR
Section 148Section 148ASection 272A(1)(d)Section 273B

272A(1)(d) for alleged non-compliance of notices, which was confirmed by the Ld. CIT(A), holding that the assessee failed to establish reasonable cause. 4. The Ld. Counsel for the assessee submitted that the imposition of penalty of Rs.20000/- u/s 272A(1)(d) and subsequently confirmed ... provided u/s 273B. The Ld.Counsel further submitted and explained hereinabove in detail, in the summary of facts, the appellant was quite prevented by a reasonable cause for the noncompliance of the alleged notices. Therefore, as defined exceptions in section 273B, the benefits of such exceptions ought to have been allowed

The Government Iti Basmathnagar Imc Society, Hingoli vs. Exemption Ward, Nanded

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

ITA 2969/PUN/2025[2018-19]Status: DisposedITAT Pune23 Jan 2026AY 2018-19

Bench: Dr.Manish Boradआयकर अपील सं. / Ita Nos.2969 & 2972/Pun/2025 Assessment Years : 2018-19 & 2019-20 The Government Iti Vs. Income Tax Officer, Basmathnagar Imc Society, Exemption Ward, Opp To Navoday Vidyalay, Range 179, Nanded Basmat Parbhani Road, Basmathnagar, Dist. Hingoli 431512 Maharashtra Pan : Aabtg2544A Appellant Respondent

For Appellant: Shri Abhay AvchatFor Respondent: Date of hearing
Section 10Section 115BSection 147Section 148Section 250Section 69A

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 orders are set aside and the effective grounds raised by the assessee for both the assessment years are allowed for statistical purposes

Kamal Basha Noor Ali Jasmine, Cuddalore vs. ITO, Ward-3, Cuddalore

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

ITA 3144/CHNY/2025[2017-18]Status: DisposedITAT Chennai23 Jan 2026AY 2017-18

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3144/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18

For Appellant: Shri S.Girish Kumar AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 250

adjudicating on merits. The FAA held that there is a delay of 37 days in filing the appeal before him and there is no reasonable cause for condoning the same. 4. On perusing the order of FAA, we noted that the assessee in Form 35 filed before the FAA stated