“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

M/S Pancham Jewellers Pvt. Ltd., Patiala vs. DCIT, CC, Patiala

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

ITA 385/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh01 May 2024AY 2015-16

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita Nos. 384 To 388/Chd/2023 "नधा"रण वष" / Assessment Years : 2014-15 To 2018-19 M/S Pancham Jewellers Pvt Ltd., Vs. The Dcit, बनाम Central Circle, # 22, Shaheed Bhagat Singh Patiala Colony, Rajpura 140401 "थायी लेखा सं./Pan No: Aadcp5151F अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Smt. Garima Singh, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 30.04.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 01.05.2024

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Smt. Garima Singh, CIT DR

Section 132Section 143(3)Section 69B

Worthy CIT(A) has erred in passing the impugned order without affording reasonable opportunity of being heard and at the same time, there existed reasonable cause for non-appearance before the Worthy CIT(A) and hence the said order deserves to be set-aside

M/S Pancham Jewellers Pvt. Ltd., Patiala vs. DCIT, CC, Patiala

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

ITA 384/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh01 May 2024AY 2014-15

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Smt. Garima Singh, CIT DR

Section 132Section 143(3)Section 69B

M/S Apeejay Education Society, Jalandhar vs. DCIT, C-1 (Exemptions), Chandigarh

In the result, the appeal is allowed

ITA 706/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh01 May 2024AY 2012-13

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr.DR

Section 142(1)Section 143(2)Section 271(1)(b)

order to ensure fairness of decision, the assessee has been given multiple opportunities to furnish documents. There is no reasonable cause for non- compliance on the part of the assessee. Rather, there has been deliberate and unrelenting non-compliance to notice u/s 142(1) dated 30.08.2019. Accordingly, I impose ... order to ensure fairness of decision, the assessee has been given multiple opportunities to furnish documents. There is no reasonable cause for non-compliance on the part of the assessee. Rather, there has been deliberate and unrelenting non compliance to notice u/s 142(1) dated 30.08.2019. Accordingly, I impose

Shriteja Mandir Trust, Kota vs. CIT Exemption, Jaipur

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

ITA 37/JPR/2024[2023-24]Status: DisposedITAT Jaipur01 May 2024AY 2023-24

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

For Appellant: Sh. Vedant Agarwal (Adv.)For Respondent: Sh. Arvind Kumar (CIT)

Section 12A

assessee filed the affidavit and relevant medical records. Considering all these aspects of the matter we find that there is a reasonable cause to the assessee in filling this appeal belatedly of 416 days. Thus, based on that evidence and records we condoned the delay and respectfully following the decision

Raj Rishi Bhartrihari Matsya University Alwar, Alwar vs. ITO Ward 1(1), Alwar

ITA 568/JPR/2023[NA]Status: DisposedITAT Jaipur01 May 2024

For Appellant: Sh. R. S. PooniaFor Respondent: Sh. Ajay Malik (CIT)

Section 10Section 80GSection 80G(5)(iii)

provided in the Act. There is no such provision nor there is any power to condone the delay after considering the reasonable reasons. A reasonable cause can be taken into cognizance for condoning the delay, if such provision is provided in the Act while considering any issue for adjudication. Therefore

Krishna Hari Gaddam, Hyderabad vs. ITO., Ward-12(1), Hyderabad

In the result, appeal of the assessee is allowed

ITA 668/HYD/2023[2020-21]Status: DisposedITAT Hyderabad30 Apr 2024AY 2020-21

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं/Ita No.668/Hyd/2023 (नििाारण वर्ा/Assessment Year: 2020-21) Krishna Hari Gaddam, Vs. Income Tax Officer, Hyderabad Ward-12(1), [Pan No. Adepg7798Q] Hyderabad अपीलार्थी/Appellant प्रत् यर्थी/Respondent नििााररती द्वारा/Assessee By: Shri H. Srinivasulu, Ar राजस् व द्वारा/Revenue By: Shri Shakeer Ahamed, Dr सुिवाई की तारीख/Date Of Hearing: 29/04/2024 घोर्णा की तारीख/Pronouncement On: 30/04/2024 आदेश / Order Per Madhusudan Sawdia, A.M: The Captioned Appeal Filed By The Assessee Is Directed Against The Order Dated 02/11/2023 Passed By The Addl/Jcit(A)-5, Chennai, (“Ld. Cit(A)”) Relating To The Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Assessee Was A Salaried Employee Of Karvy Stock Broking Limited. For The Year Under Consideration, The Assessee Fled His Return Of Income, Declaring A Total Income Of Rs. 86,10,680/- & Paid Total Income Tax Of Rs. 27,37,674/-, Consisting Of Tax Deducted At Source (“Tds”) Of Rs. 15,11,384/- & Self Assessment Tax Of Rs.12,26,290/-. The Cpc Bengluru (“Cpc”) In The Intimation U/S 143(1) Of The Income Tax Act, 1961 (“The Act”), Dt. 08/05/2021 Did Not Give Credit Of Rs. 13,50,000/- Out Of Total Tds Of Rs. 14,75,000/- Deducted By M/S. Karvy Stock Broking Limited U/S. 192 Of The Act, Contending That Form 26As Does Contains The Details Of Tds Of Rs. 13,50,000/- & Finally Raised A Demand Of Rs.14,17,500/-.

For Appellant: Shri H. Srinivasulu, ARFor Respondent: Shri Shakeer Ahamed, DR

Section 143(1)Section 192

liable for punishment with rigorous imprisonment under section 276B. 8.9 That said, both impositions of penalty and prosecution are subject to the defence of 'reasonable cause' as provided in sections 273B and 278AA of the Act, respectively. 9. Importantly, section 201 (2), provides that where a person who, although required

Mahaveerchand, Bangalore vs. Income Tax Officer, Ward-5(2)(1), Bangalore

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

ITA 402/BANG/2024[2016-17]Status: DisposedITAT Bangalore30 Apr 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Shri Sudheendra B.R., A.RFor Respondent: Shri Narendra Kumar Naik, D.R

Section 147Section 271(1)(c)

filing the appeal of about 234 days. The ld. CIT(A) dismissed the appeal of assessee without condoning the delay by holding that no reasonable cause was made out. 3. Before this Tribunal, the assessee has filed an affidavit stating that all the notices issued to the assessee were sent

JCIT (It) (OSD)-4(1)(2), Mumbai vs. Arun Rangachari, Mumbai

In the result, appeal of the Revenue is dismissed and

ITA 2393/MUM/2019[2009-10]Status: DisposedITAT Mumbai30 Apr 2024AY 2009-10

Section 132(4)Section 147Section 254(2)Section 9(1)(i)

correct in recalling its earlier order dated 22.04.2022 vide order dated 03.11.2023. Cross objections are beyond the prescribed time limit and without any reasonable cause for delay and also drew reference to the provision of section 253(4) of the Act. Objected the arguments put forth by the Ld.AR that ... this scope are out rightly rejected. 20. Coming to the issue, whether cross objections are beyond the prescribed time limit and was there any reasonable cause of delay, first of all, once the assessee had stated that it has not received the grounds of appeal and had applied for Form

Vijay Kumar Agarwal, Bahraich vs. ITO-1, Bahraich

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

ITA 93/LKW/2024[2017-18]Status: DisposedITAT Lucknow29 Apr 2024AY 2017-18

Bench: Shri Sudhanshu Srivastavaa.Y. 2017-18 Vijay Kumar Agarwal, Vs. The Income Tax Officer-1, Jubliganj, Station Road, Bahraich. Nanpara, Bahraich Pan Agypa 3333Q (Appellant) (Respondent) Appellant By None Present For The Assessee Respondent By Shri Sanjeev Krishna Sharma, Addl. Cit( Dr) Date Of Hearing 09/04/2024 Date Of Pronouncement 29/04/2024 O R D E R

Section 143(2)Section 153ASection 271ASection 4Section 44ASection 69A

raising the following ground of appeal: “(1) The Ld. C.I.T. (A) failed to appreciate that there was a reasonable cause for not making any compliance in the appellate proceeding as Assessee was not familiar with e- proceedings and living in remote area. (2) The Ld. C. I. T. (A) failed

Latabai Kacharu Tambere, Nashik vs. Assessment Unit, Income Tax Department

Appeal is allowed for statistical purposes in above terms

ITA 149/PUN/2024[2018-19]Status: DisposedITAT Pune29 Apr 2024AY 2018-19

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta

Section 147Section 250(6)

learned NFAC has rightly refused to condone 30 days delay in filing of the assessee’s lower appeal as not sufficiently explained with reasonable cause. The fact however remains that not only the learned NFAC has not given due consideration of various judicial precedents and more particularly, 2 ITA.No.149/PUN

Vinayak Tukaram Koli, Panvel vs. ITO, Ward-5, Panvel

Appeal is allowed for statistical purposes in above terms

ITA 1416/PUN/2023[2013-14]Status: DisposedITAT Pune29 Apr 2024AY 2013-14

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Prateek Jha

Section 147Section 250(6)

that the learned NFAC has refused to condone 27 days delay in filing of the assessee’s lower appeal as not sufficiently explained with reasonable cause. Learned DR vehemently supported the NFAC’s order that assessee’s Form No.35 2 ITA.No.1416/PUN./2023 had not shown any cogent reason

Candid Industries Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 83/HYD/2024[2014-15]Status: DisposedITAT Hyderabad29 Apr 2024AY 2014-15

Bench: Shri Laliet Kumar(Through Virtual Mode) & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.83/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2014-15) Candid Industries Limited Vs. Dy. C. I. T. Plot No.1, Survey No.308, Circle 1(1) Venkateswara Co- Hyderabad Operative, Industrial Estate, Jeedimetla, Hyderabad Pan:Aaace4493Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Mv Joshi, Ca Appeared For Shri P. Murali Mohan Rao, Ca रधजस् व द्वधरध/Revenue By:: Ms. Sheetal Sarin, Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2024 घोर्णध की तधरीख/Pronouncement: 29/04/2024

For Appellant: Shri MV Joshi, CA appeared for Shri P. MuraliFor Respondent: : Ms. Sheetal Sarin, DR

Section 139(1)Section 142(1)Section 144Section 147Section 148

assessee also filed an appeal before the ld. CIT(A) with a delay of 163 days without any reasonable cause. Under these circumstances when the assessee has no regard for the statutory notices, the order passed by the ld. CIT(A) dismissing the appeal in limini is justified

Shiv Agrevo Ltd, Kota vs. DCIT Circle-2, Kota

In the result, the appeal of the assessee is allowed

ITA 623/JPR/2023[2015-16]Status: DisposedITAT Jaipur29 Apr 2024AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Devang Garvieya, AdvocateFor Respondent: Shri Anoop Singh, Addl CIT-DR

Section 145(3)Section 271(1)Section 274

points out to a discrepancy of a substantial amount of Rs.40,84,751/- unlike other years. The appellant has not been able to establish reasonable cause for such failure as required u/s 273B of the I.T. Act. In such circumstances, the grounds of appeal disputing the imposition of penalty

Ambience Private Limited, New Delhi vs. Income Tax Office, Range-73, New Delhi

The appeal of the assessee is allowed

ITA 558/DEL/2022[2010-11]Status: DisposedITAT Delhi29 Apr 2024AY 2010-11

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharmaassessment Year: 2010-11 Ambience Private Limited, Vs Ito, L4, Green Park Extension, Range-73, New Delhi – 110 016. New Delhi.

For Appellant: Shri Anand Chaudhuri, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR

Section 194JSection 194J(1)(ba)Section 201(1)Section 271CSection 273B

credit, it is respectfully stated that the assessee is fully covered by the provisions of section 273B which states that if there is a reasonable cause then no penalty u/s 271C should be imposed. Further, the Ld. A.O. has not appreciated the fact that there is no contumacious conduct ... sake of brevity, we are not repeating the detailed submission as referred to in preceding paragraphs which clearly establishes that the assessee has a reasonable cause for not deducting the TDS as per the provisions of Section 273B of the Income Tax Act.” 3 4. After considering the explanation given

Balwinder Singh, Sangrur vs. ITO, Ward, Sunam

In the result, the appeal of the assessee is allowed

ITA 252/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh26 Apr 2024AY 2011-12

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Dev Ahuja, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 139Section 139(1)Section 143(3)Section 144Section 148Section 271F

assessee, as the case may be for any failure referred to inter-alia in section 271F if he proves that there was a reasonable cause for such failure. 6.4 It was submitted that keeping in view the facts and circumstances of the case as submitted above, it was prayed before ... assessee, as the case may be for any failure referred to inter-alia in section 271F if he proves that there was a reasonable cause for such failure. 6.6 In the case of Hakim Khan Sumergadh Bibalsar Jalore, Rajasthan Vs. ITO I.T.No.71 & 74/Ahd/2021 A.Y.2011-12, the Tribunal has held that

Ranpur Mahamaya Khadi Gramodyog Samity, Bankura vs. ITO, Ward-2(1) Exemption, Durgapur

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

ITA 282/KOL/2024[2018-19]Status: DisposedITAT Kolkata26 Apr 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra]

remain vigilant and file necessary documents in support of its grounds of appeal and should not take any further adjournment, unless otherwise required for reasonable cause. In case after providing sufficient opportunity to the assessee, there is no compliance before the ld. CIT(A), then

Mrs. Beant Kaur Juneja, Nagpur vs. Income Tax Officer, Ward-4(2), Nagpur

The appeal of the assessee is ALLOWED

ITA 18/NAG/2023[2017-18]Status: DisposedITAT Nagpur25 Apr 2024AY 2017-18

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 018/Nag/2023 निर्धारण वषा / Assessment Year : 2017-18 Beantkaur Avtarsingh Juneja Hp Petrol Pump, Dosar Bhavan, C. A. Road, Nagpur-440002. Pan: Aflpj2956E . . . . . . . अपीलार्थी / Appellant

For Appellant: None for the AssesseeFor Respondent: Mr Abhay Marathe [‘Ld. DR’]

Section 143(1)Section 24Section 246A(1)(a)Section 250Section 253(1)(a)Section 271BSection 273BSection 274(1)Section 44A

filing ITR for AY 2017-18 i.e. 07/11/2017. In response thereto the assessee neither made any submission nor any representation explaining reasonable cause beyond delay in filing TAR owning to which the Ld. AO culminated the proceedings by an order dt. 23/03/2020 imposing penalty of ₹1,50,000/- being ... appeal the Ld. NFAC provided as much as six opportunities from January, 2021 to March, 2022, however, the assessee failed to effectively establish the reasonable cause beyond delayed filing of TAR to the satisfaction of the first appellate authority. The assessee’s reasoning that due to legal dispute over ownership

Muktyar Singh Thakur, Adilabad vs. ITO., Ward-1, Adilabad

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

ITA 207/HYD/2024[2016-17]Status: DisposedITAT Hyderabad25 Apr 2024AY 2016-17

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No. 207/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Muktyar Singh Thakur Vs. Income Tax Officer Adilabad Ward-1 Pan:Akxpt0168M Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S Phanindra राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 25/04/2024 घोषणा की तारीख/Pronouncement: 25/04/2024 आदेश/Order

For Appellant: Advocate S PhanindraFor Respondent: : Smt. Sheetal Sarin, DR

Section 142(1)Section 147Section 148Section 5

holding that the reasons given by the assessee for not filing the appeal within time allowed under the Act does not come under reasonable cause and further, the assessee should be more vigilant and take necessary steps to file the appeal as per the prescribed method. Since, the appellant ... filed within the time Page 5 of 6 ITA No 207 of 2024 Muktyar Singh Thakur allowed under the Act comes under reasonable cause as provided under the Act for condonation of delay and thus, in our considered view, the learned CIT (A) NFAC ought to have condoned the delay

Haja Moinudeen, Puducherry vs. ITO, Ward 4, Puducherry

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

ITA 1598/CHNY/2023[2017-18]Status: DisposedITAT Chennai25 Apr 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1598/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 Shri Haja Moinudeen, The Income Tax Officer, No.6, Subbiah Salai, Vs. Ward 4, Puducherry – 605 001. Puducherry. Pan: Aabph 0929C (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 25.04.2024 घोषणा क" तारीख/Date Of Pronouncement : 25.04.2024

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT

Section 143(3)Section 250(6)

under mental pressure leading to illness. The ld.counsel stated that this case looks for mercy and even there is reasonable cause in filing of appeal with a delay of 569 days. Admittedly, the appeal was filed on 28.12.2023 with a delay of 569 days. 2.1 On the other hand ... Senior DR contested the condonation petition and stated that there is no reasonable cause. 2.2 After hearing rival contentions and going through the facts of the case, we are of the view that delay can be condoned with a cost of Rs.15,000/-. Hence, seeing circumstances and cost adduced

Incometax Officer, Nungambakkam vs. Aaditra Foundations, Anna Nagar, Chennai

The appeal stand dismissed

ITA 1081/CHNY/2023[2018-19]Status: DisposedITAT Chennai25 Apr 2024AY 2018-19

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1081/Chny/2023 (िनधा*रणवष* / Assessment Year: 2018-19) Ito M/S. Aaditra Foundations बनाम/ Old No.76 New No.54, 1St Floor, U Non-Corporate Ward-7(1) Vs. Chennai. Block, Anna Nagar, Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aayfa-3288-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri D. Hema Bhupal (Jcit)-Ld. Sr. Dr " थ"कीओरसे/Respondent By : Shri Y. Sridhar (Ca)- Ld.Ar सुनवाई की तारीख/Date Of Hearing : 20-03-2024 घोषणा की तारीख /Date Of Pronouncement : 25-04-2024

For Appellant: Shri D. Hema Bhupal (JCIT)-Ld. Sr. DRFor Respondent: Shri Y. Sridhar (CA)- Ld.AR

Section 147Section 46A

assessee’s business was closed down during November. 2017 and it had already surrendered its PAN. The same could be considered to be a reasonable cause for non-representation during assessment proceedings. It also emerges that the assessee is holding current account. In case of surplus funds beyond certain threshold