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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

The Karnataka Chemists & Druggists Association®, Bangalore vs. Income Tax Officer, Ward-5(3)(2), Bangalore

ITA 699/BANG/2024[2013-14]Status: DisposedITAT Bangalore04 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Respondent: Shri Ravishankar, A.R
Section 147Section 249(3)Section 271(1)(b)Section 271(1)(c)

case. He submitted that the 1d. CIT(A), NFAC has failed to appreciate that the reasons furnished for delay in filing the appeals constitutes ‘reasonable cause' and ought to have condoned the delay by exercising the powers conferred u/s 249(3) of the Act, on the facts and circumstances ... provided for penalty appeal. However, the NFAC dismissed the quantum & penalty appeal together on the same day. Thus, the assessee was prevented by reasonable cause in filing the condonation petition with regard to the penalty appeals. He submitted that the professional who filed the appeal against the quantum order

Nirchem Dyes and Chemicals Pvt Ltd, Mumbai vs. Income-Tax Officer 7(2)(4), Mumbai

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

ITA 267/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Jun 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18

For Appellant: Mr. Akash KumarFor Respondent: Mr. Ashok Kumar Ambastha, Sr. DR
Section 68

pass the impugned. In our the Ld. CIT(A) pass the impugned. In our opinion, there is a reasonable opinion, there is a reasonable cause for non-compliance before the compliance before the Ld. CIT(A). Further, in Ld. CIT(A). Further, in view of the undertaking

Abhitech Energycon Ltd, Mumbai vs. ACIT Central Circle 1 (1)(1), Mumbai

In the result, appeals filed by the assessee for the assessment years

ITA 3120/MUM/2023[2016-17]Status: DisposedITAT Mumbai04 Jun 2024AY 2016-17

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri K GopalFor Respondent: Shri Manoj Kumar Sinha
Section 143(1)Section 143(1)(a)Section 154Section 249Section 250Section 80I

learned CIT(A). 5. On the other hand, the learned Departmental Representative vehemently relied upon the impugned order and submitted that there was no reasonable cause for condoning the huge delay of 1128 days. 6. We have considered the submissions of both sides and perused the material available on record ... aforesaid basis. However, the learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee on the basis that there is no reasonable cause for condoning the delay in filing the appeal. 7. From the perusal of the paper book filed by the assessee, we find that

Abhitech Energycon Ltd, Mumbai vs. ACIT Central Circle - 1(1)(1), Mumbai

In the result, appeals filed by the assessee for the assessment years

ITA 3119/MUM/2023[2015-16]Status: DisposedITAT Mumbai04 Jun 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri K GopalFor Respondent: Shri Manoj Kumar Sinha
Section 143(1)Section 143(1)(a)Section 154Section 249Section 250Section 80I

learned CIT(A). 5. On the other hand, the learned Departmental Representative vehemently relied upon the impugned order and submitted that there was no reasonable cause for condoning the huge delay of 1128 days. 6. We have considered the submissions of both sides and perused the material available on record ... aforesaid basis. However, the learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee on the basis that there is no reasonable cause for condoning the delay in filing the appeal. 7. From the perusal of the paper book filed by the assessee, we find that

R P Buildwell Private Limited, Delhi vs. Income Tax Officer, New Delhi

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

ITA 14/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Jun 2024AY 2017-18

Bench: Him As Assessee Merely Needed A Copy Of Assessment Order.

Section 144

appeal. 4. After appreciating the order of the Ld. CIT(A), we find that the Ld. CIT(A) had stretched too far the expression ‘reasonable cause’ while examining the plea of the assessee to explain the delay in filing the appeal. Assessee had come with a plea that

Sanatan Dharam Parcharak Sabha Regd., Ludhiana vs. Commissioner of Income Tax (Exemptions), Chandigarh

The appeal of the assessee is allowed for statistical

ITA 278/CHANDI/2024[2023-24]Status: DisposedITAT Chandigarh03 Jun 2024AY 2023-24

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 12ASection 282(1)

Income Tax (Exemptions), Chandigarh is against law and facts on the file in as much as the appellant was prevented by a sufficient and reasonable cause in not responding to the impugned notices as the appellant did not receive any such notice.” 3. At the outset, the ld. Counsel

Satpuda Foundation, Amravati vs. Income Tax Officer, Ward-2, Nagpur

In the result, assessee’s appeal is allowed

ITA 143/NAG/2021[2017-18]Status: DisposedITAT Nagpur03 Jun 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. Moryani a/wFor Respondent: Shri Abhay Y. Marathe
Section 11Section 11(2)Section 12ASection 139(1)Section 143(2)Section 143(3)Section 234A

Commissioners will while entertaining such belated applications in filing Form no.10B shall satisfy themselves that the assessee was prevented by reasonable cause from filing such application within the stipulated time. Further, all such applications shall be disposed off by 30.09.2019." Further, the CBDT had issued another circular on this issue ... para 4(ii) supra. Since, in this case, the appellant has neither brought out any case before the undersigned that it was prevented by reasonable cause from filing such application within the stipulated time and further considering the fact that the power to condone the delay has been entrusted

Raichand Kothari Foundation, Kolkata vs. CIT(Exemption), Kolkata

In the result, all the appeal of the assessee(s) are allowed for statistical purposes

ITA 794/KOL/2024[00]Status: DisposedITAT Kolkata03 Jun 2024

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1269/Kol/2023 Narsinghdas Rawalwasia Commissioner Of Income Tax Charitable Trust Vs (Exemptions), Kolkata Ground Floor 4/1, Middleton Street Kolkata - 700071 [Pan : Aadtn4041R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R
Section 80GSection 80G(5)

opposing the condonation of delay, in the larger interest of justice condone the delay finding it to be on account of reasonable cause and admit the appeal for adjudication. 3. As the issues involved in all these appeals are identical, they were heard together and are being disposed

M/S Tattva Heritage Foundation, Kolkata vs. CIT(Exemption), Kolkata

In the result, all the appeal of the assessee(s) are allowed for statistical purposes

ITA 766/KOL/2024[00]Status: DisposedITAT Kolkata03 Jun 2024

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1269/Kol/2023 Narsinghdas Rawalwasia Commissioner Of Income Tax Charitable Trust Vs (Exemptions), Kolkata Ground Floor 4/1, Middleton Street Kolkata - 700071 [Pan : Aadtn4041R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R
Section 80GSection 80G(5)

opposing the condonation of delay, in the larger interest of justice condone the delay finding it to be on account of reasonable cause and admit the appeal for adjudication. 3. As the issues involved in all these appeals are identical, they were heard together and are being disposed

Avijit Roy Memorial Foundation, Kolkata vs. CIT(Exemption), Kolkata

In the result, all the appeal of the assessee(s) are allowed for statistical purposes

ITA 671/KOL/2024[00]Status: DisposedITAT Kolkata03 Jun 2024

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1269/Kol/2023 Narsinghdas Rawalwasia Commissioner Of Income Tax Charitable Trust Vs (Exemptions), Kolkata Ground Floor 4/1, Middleton Street Kolkata - 700071 [Pan : Aadtn4041R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R
Section 80GSection 80G(5)

opposing the condonation of delay, in the larger interest of justice condone the delay finding it to be on account of reasonable cause and admit the appeal for adjudication. 3. As the issues involved in all these appeals are identical, they were heard together and are being disposed

Shree Karunanidhan Seva Trust, Kolkata vs. CIT(Exemption), Kolkata

In the result, all the appeal of the assessee(s) are allowed for statistical purposes

ITA 1471/KOL/2023[00]Status: DisposedITAT Kolkata03 Jun 2024

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1269/Kol/2023 Narsinghdas Rawalwasia Commissioner Of Income Tax Charitable Trust Vs (Exemptions), Kolkata Ground Floor 4/1, Middleton Street Kolkata - 700071 [Pan : Aadtn4041R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R
Section 80GSection 80G(5)

opposing the condonation of delay, in the larger interest of justice condone the delay finding it to be on account of reasonable cause and admit the appeal for adjudication. 3. As the issues involved in all these appeals are identical, they were heard together and are being disposed

Saraogi Udyog Foundation, Kolkata vs. CIT(A), Exemption, Kolkata

In the result, all the appeal of the assessee(s) are allowed for statistical purposes

ITA 1470/KOL/2023[00]Status: DisposedITAT Kolkata03 Jun 2024

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1269/Kol/2023 Narsinghdas Rawalwasia Commissioner Of Income Tax Charitable Trust Vs (Exemptions), Kolkata Ground Floor 4/1, Middleton Street Kolkata - 700071 [Pan : Aadtn4041R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R
Section 80GSection 80G(5)

opposing the condonation of delay, in the larger interest of justice condone the delay finding it to be on account of reasonable cause and admit the appeal for adjudication. 3. As the issues involved in all these appeals are identical, they were heard together and are being disposed

Narsinghdas Rawalwasia Charitable Trust., Kolkata vs. CIT(E), Kolkata.

In the result, all the appeal of the assessee(s) are allowed for statistical purposes

ITA 1269/KOL/2023[2023-24]Status: DisposedITAT Kolkata03 Jun 2024AY 2023-24

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1269/Kol/2023 Narsinghdas Rawalwasia Commissioner Of Income Tax Charitable Trust Vs (Exemptions), Kolkata Ground Floor 4/1, Middleton Street Kolkata - 700071 [Pan : Aadtn4041R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R
Section 80GSection 80G(5)

opposing the condonation of delay, in the larger interest of justice condone the delay finding it to be on account of reasonable cause and admit the appeal for adjudication. 3. As the issues involved in all these appeals are identical, they were heard together and are being disposed

Pearl Beach Promoters Private Limited, Chennai vs. AO, Corporate Ward-5(1), Chennai

The appeals stand partly allowed

ITA 1290/CHNY/2023[2017-18]Status: DisposedITAT Chennai03 Jun 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalआयकरअपीलसं./Ita Nos. 1289 & 1290/Chny/2023 िनधा"रण वष"/Assessment Year:2017-2018

For Appellant: Shri M. Karunakaran, AdvocateFor Respondent: Shri ARV Srinivasan, Addl. CIT
Section 143(3)Section 269SSection 271DSection 271ESection 273BSection 275

reason to impose impugned penalties. 4 3.5 However, Ld. CIT(A) held that in terms of Sec.273B, the assessee failed to establish reasonable cause for breach. The payments to labor and other expenditure at the sites were not foreseen events. Therefore, Ld. CIT(A) confirmed penalty except to the extent

Pealrl Beach Promoters Private Limited, Chennai vs. AO, Corporate Ward-5(1), Chennai

The appeals stand partly allowed

ITA 1289/CHNY/2023[2017-18]Status: DisposedITAT Chennai03 Jun 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalआयकरअपीलसं./Ita Nos. 1289 & 1290/Chny/2023 िनधा"रण वष"/Assessment Year:2017-2018

For Appellant: Shri M. Karunakaran, AdvocateFor Respondent: Shri ARV Srinivasan, Addl. CIT
Section 143(3)Section 269SSection 271DSection 271ESection 273BSection 275

reason to impose impugned penalties. 4 3.5 However, Ld. CIT(A) held that in terms of Sec.273B, the assessee failed to establish reasonable cause for breach. The payments to labor and other expenditure at the sites were not foreseen events. Therefore, Ld. CIT(A) confirmed penalty except to the extent

Chirag Balkrishna Patel, Panchmahal vs. The Income Tax Officer, Ward-1 (Previously Ward-3(1)(2) Vadodara), Godhra

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

ITA 283/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad31 May 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2017-18 Chirag Balkrishna Patel Income Tax Officer, 15, Adarsh Society, Vs Ward-1, Godhra Vadodara Road, (Previous, Ito, Ward-3(1)(2), Halol, 389350 Vadodra) Gujarat Pan: Butpp1753 K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Jigar Adhiyaru, Ar Revenue By : Shri N.J. Vyas, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 16/05/2024 घोषणा क" तार"ख /Date Of Pronouncement: 31/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal Is Filed By The Assessee Against The Order Dated 31-10-2023 Passed By The Commissioner Of Income Tax (Appeals) – [National Faceless Appeal Centre (Nfac)] (Hereinafter Referred As “Cit(A)”) Which Was Preferred By The Assessee Against The Order Passed By The Assessing Officer (Hereinafter Referred As “The Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As “The Act”).

For Appellant: Shri Jigar Adhiyaru, ARFor Respondent: Shri N.J. Vyas, Sr.DR
Section 143(3)Section 69A

there was a delay of 43 days in filing the appeal. Since delay was not properly explained by the assessee with a sufficiently reasonable cause, CIT(A) did not condone the delay. Since the delay was not condoned the appeal was admitted by the CIT(A) for adjudication on merits

Fatehsinh Udesinh Parmar, at. Dena, Vadodara vs. Income Tax Officer, Income Tax Officer Ward

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

ITA 772/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad31 May 2024AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year: 2015-16 Fatehsinh Udesinh Parmar, The Income Tax Officer, At. Dena Para, Vs Ward-3(1)(4), Hami Dena Road, Vadodara Vadodara-390022 Gujarat Pan: Awwpp2183 M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Anil B Thakkar, Ar Revenue By : Shri N.J. Vyas, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 15/05/2024 घोषणा क" तार"ख /Date Of Pronouncement: 31/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal Is Filed By The Assessee As Against The Order Dated 4-8-2023 Passed By The Commissioner (Appeals), National Faceless Appeal Centre, Delhi, (Hereinafter Referred To As 'Nfac'), Dismissing The Appeal Against The Order Penalty Passed By The Assessing Officer (Hereinafter Referred As “Ao”) Under Section 271(1)(B) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act') Relating To The Assessment Year (A.Y) 2015-16. Fatehsinh Udesinh Parmar Vs. Ito Asst. Year: 2015-16

For Appellant: Shri Anil B Thakkar, ARFor Respondent: Shri N.J. Vyas, Sr.DR
Section 142(1)Section 144Section 147Section 148Section 271(1)(b)Section 273B

imposition of penalties under section 271(1)(b) is not mandatory, rather it is discretionary, because if the assessee proves that there was a 'reasonable cause' for the said failure, then the assessing officer ought to have considered the same and then proceed with levying penalties. A perusal ... imposed in certain cases'. A careful reading of section 273B encompasses that certain penalties 'shall' not be imposed in cases where 'reasonable cause' is successfully pleaded. It is seen that penalty imposable under section 271(1)(b) also included therein. 7.1. By the said provisions, the Parliament has unambiguously made

Lions Club of Pune Supreme Trust, Narayan Peth, Laxmi Raod, Pune vs. Commissioner of Income Tax Exemption, Pune, Income Tax Office, Pmt Building, Shankar Seth Road

ITA 369/PUN/2024[Not Applicable]Status: DisposedITAT Pune31 May 2024

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshalilions Club Of Pune Supreme Trust 710, Narayan Peth, Laxmi Road, Pune-411030. . . . . . . . अपीलार्थी / Appellant Pan:Aabtl2778B बनाम / V/S. Commissioner Of Income Tax-Exemption, . . . . . . . . प्रत्यर्थी / Respondent Pune द्वारा / Appearances Assessee By : Mr Pramod Shingte [‘Ld. Ar’] Revenue By : Mr Keyur Patel [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 31/05/2024 घोषणा की तारीख / Date Of Pronouncement : 31/05/2024 आदेश / Order Per G. D. Padmahshali, Am; By Present Appeal The Assessee Trust Challenges Rejection Din & Order No. Itba/Exm/F/Exm45/2022-23/1050413965(1) Dt. 04/03/2023 Passed By The Commissioner Of Income Tax-Exemption, Pune [For Short ‘Cit(E)’] U/S 80G(5) Of The Income-Tax Act, 1961 [For Short ‘The Act’]

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘LD. DR’]
Section 80GSection 80G(5)

attended. The circumstance suggest without an iota of doubt that, the non-compliance was on the part of assessee was undeliberate & attributable to reasonable cause there behind, for which the appellant seeks one more opportunity to represent its case and comply with the requirements of law and cure the defects

Ashit Kumar Deb, Kolkata vs. ITO, Ward-25(2), Kolkata

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

ITA 283/KOL/2024[2017-18]Status: DisposedITAT Kolkata31 May 2024AY 2017-18

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Rakesh Mishra, Hon’Blei.T.A. No. 283/Kol/2024 Assessment Year: 2017-18 Ashit Kumar Deb Income Tax Officer, Ward-25(2), 2/240 Sree Colony Vs Kolkata Regent Estate Baghajatin Kolkata - 700092 [Pan : Aqcpd6452F] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Arvind Agarwal, Advocate Revenue By : Smt. Monalisha Pal Mukherjee, Jcit, D/R सुनवाई क" तारीख/Date Of Hearing : 30/05/2024 घोषणा क" तारीख /Date Of Pronouncement: 31/05/2024 आदेश/O R D E R Per Sonjoy Sarma: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”) Dt. 02/09/2022, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2017-18. 2. At The Time Of Hearing The Registry Has Informed That The Present Appeal Filed By The Assessee Is Time Barred By 104 Days. The Assessee Prayed For Condonation Of The Delay. The Reasons Are Placed On Record. We, After Perusing The Same As Well As Material Available On Record Find Merit In The Reasonable Cause Stated By The Assessee, Which Prevented Him To File The Appeal Within The 2

For Appellant: Shri Arvind Agarwal, AdvocateFor Respondent: Smt. Monalisha Pal Mukherjee, JCIT, D/R
Section 250

delay. The reasons are placed on record. We, after perusing the same as well as material available on record find merit in the reasonable cause stated by the assessee, which prevented him to file the appeal within the 2 I.T.A. No. 283/Kol/2024 Assessment Year: 2017-18 Ashit Kumar Deb statutory

M/S. Vasavi Credit Co-Operative Society Limited, Raichur vs. Income-Tax Officer, Ward-1, Raichur

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

ITA 350/BANG/2024[2020-21]Status: DisposedITAT Bangalore31 May 2024AY 2020-21

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Smt. Sunaina Bhatia, AdvocateFor Respondent: Shri Ganesh R Ghale, Standing
Section 80P(2)(a)

present case, the assessee has explained the reason that caused delay in filing appeal before the Ld.CIT(A). The reason cited is a reasonable cause on the part of the assessee for not filing the appeal within the period of limitation. One should keep in mind that while construing