← All Phrases

“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

Johar Gadly Alias Zohar Mohammad Bhai Through Legal Heir Rashida Gadly, Patna vs. ACIT, Circle-2, Patna

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

ITA 295/PAT/2025[2017-18]Status: DisposedITAT Patna15 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.295/Pat/2025 Assessment Year: 2017-18 Johar Gadly Alias Zohar Mohammad Bhai ……………....Appellant Shop No.5, Aditya Arcade, Exhibition Road, Patna, Bihar- 800001. [Pan: Abopb7542H] Vs. Acit, Cc-2, Patna………….…..……………..………………….…..... Respondent Appearances By: Shri Hiresh Karan, Adv. Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 13, 2026 Date Of Pronouncing The Order : January 15, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 31.01.2025 Passed By The Cit(A)-3, Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring A Total Income Of ₹2,94,100. The Assessing Officer Completed Assessment U/S 143(3) By Determining Total Income At Rs.8,63,000/- After Making Addition Of Rs.11,57,190/- On Account Of Unexplained Investment U/S 69 Of The Act.

Section 143(3)Section 250Section 69

condonation of delay, explaining the reasons for such delay. After considering the submissions and the reasons stated, we are satisfied that there existed a reasonable cause preventing the assessee from filing the appeal within the prescribed time. Accordingly, the delay of 79 days is condoned. 5. It was submitted

Manoj Dwivedi, Lucknow vs. ITO-3(1), Lucknow

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

ITA 619/LKW/2025[2016-17]Status: DisposedITAT Lucknow15 Jan 2026AY 2016-17

Bench: SHRI KUL BHARAT (Vice President), SHRI ANADEE NATH MISSHRA (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.AFor Respondent: Shri Amit Kumar, CIT(DR)
Section 143(2)

perspective. He further submitted that the Ld. CIT(A) failed to condone the delay, which had occurred due to the Page 3 of 6 “reasonable cause.” He also submitted that if an opportunity is granted to the assessee, he would substantiate and explain the source before the lower authorities regarding

Siddhart Shankar, Indirapuram vs. The ITO Ward- 2(2)(4), Ghaziabad, Hapur Chungi

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 6252/DEL/2025[2012-13]Status: DisposedITAT Delhi14 Jan 2026AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2012-13 Siddhart Shankar, Vs. Ito, Ward 2(2)(4), L-1202, Jaipuria Sunrise Green, Ghaziabad 12-A, Ahinsha Khand, Hapur Chungi, Indirapuram, Ghaziabad Ghaziabad – 201 014 - Up (Pan: Blcps5171A) (Appellant) (Respondent) Appellant By : None Respondent By : Sh. Ajay Kumar Arora, Sr. Dr

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 144

After hearing the Ld. DR and keeping in view the cause of delay in filing the appeal, we are of the considered view that reasonable cause has been attributed to the assessee for delay in filing the appeal, hence, in the interest of justice, we condone the delay in filing

Gurmeet Chadha, Haryana vs. ITO Ward 1(3) Gurgaon, Gurgaon

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 6243/DEL/2025[2019-20]Status: DisposedITAT Delhi14 Jan 2026AY 2019-20

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2019-20 Gurmeet Chadha, Vs. Ito, Ward 1(3), Gurgaon J-1312 A, Palam Vihar, Hsiidc Building, 4Th Floor, Udyog Vihar, Gurgaon – 122017 Haryana Phase-V, Gurugram, (Pan: Blcps5171A) Haryana, Gurgaon (Appellant) (Respondent) Appellant By : Sh. I.P. Bansal, Adv. Respondent By : Sh. Ajay Kumar Arora, Sr. Dr

For Appellant: Sh. I.P. Bansal, AdvFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 144Section 144BSection 147

this the assessee has filed the petition for condonation. After hearing both the sides and perusing the records, we are of the view that reasonable cause has been attributed to the assessee for filing the belated appeal before the Tribunal, hence, in the interest of justice, we condone the delay

Dy. Commissioner of Income Tax, Central Circle-17, Delhi vs. M/S Mani Capital Limited, Kanpur

In the result, the appeal of the Revenue is dismissed

ITA 3856/DEL/2025[2015-16]Status: DisposedITAT Delhi14 Jan 2026AY 2015-16

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2015-16 Dcit, Cc-17, Vs. M/S Mani Capital Limited, New Delhi 14, Ratan Mahal, 15/197, Room No. 244, E-2, Ara Civil Lines, Kanpur, Centre Uttar Pradesh Jhandewalan Extn., (Pan: Aaacd4969L) New Delhi (Appellant) (Respondent)

Section 153ASection 153CSection 153C(1)Section 69A

controvert the aforesaid plea of the Revenue. After hearing the rival contentions and perusing the records, we are of the considered view that reasonable cause has been attributed to the Revenue which was not intentional, hence, we condone the delay of 73 days in filing the appeal before the Tribunal

Swavalamban Avam Swabhimaan Foundation, Delhi vs. Commissioner of Income Tax (Exemption ), New Delhi

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

ITA 3331/DEL/2025[2023-24]Status: DisposedITAT Delhi14 Jan 2026AY 2023-24

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 11Section 12ASection 12A(1)Section 12A(1)(ac)Section 13(1)(c)Section 80G

submissions and the reasons explained by the assessee in filing the appeals with the delay of 11 days we find that the assessee has reasonable cause in not presenting these appeals in time and accordingly delay of 11 days in filing these appeals is condoned and the appeals are admitted

Swavalamban Avam Swabhimaan Foundation, Delhi vs. Commissioner of Income Tax (Exemption), Delhi

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

ITA 3328/DEL/2025[2023-24]Status: DisposedITAT Delhi14 Jan 2026AY 2023-24

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 11Section 12ASection 12A(1)Section 12A(1)(ac)Section 13(1)(c)Section 80G

submissions and the reasons explained by the assessee in filing the appeals with the delay of 11 days we find that the assessee has reasonable cause in not presenting these appeals in time and accordingly delay of 11 days in filing these appeals is condoned and the appeals are admitted

Ashok Mishra, Delhi vs. ITO Ward-43(1), Delhi

In the result, the assesee’s appeal is allowed for statistical purposes

ITA 2444/DEL/2025[2021-22]Status: DisposedITAT Delhi14 Jan 2026AY 2021-22

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2021-22 Ashok Mishra, Vs. Ito, Ward 43(1), 81-82/3, Gali Bandook Wali, Civic Centre, Metro Market, Chandni Chowk, New Delhi – 110 002 Central Delhi Delhi – 110 006 (Pan: Apcpm0132J) (Appellant) (Respondent)

For Appellant: Ms Tanya Shruti, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(1)

direct him to allow one more opportunity to assessee to file condonation petition and then accordingly decide the condonation petition whether there exist any reasonable cause or not. The Ld. CIT(A), if find reasonable cause in the condonation petition, the delay in dispute be condoned and thereafter, issue

Anil Dalal, Rohtak vs. ITO Ward 3, Rohtak

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 2402/DEL/2025[2013-2014]Status: DisposedITAT Delhi14 Jan 2026AY 2013-2014

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2013-14

For Appellant: Sh. Umang Sahai, Adv. & Sh. Vaibhav AgarwalFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 144BSection 147Section 148

failed to utilize the updated address available in the system and did not take steps to effect proper service. Therefore, there existed a reasonable cause for non-compliance and due to non-receipt of notice u/s. 148 the assessee was prevented by sufficient and reasonable cause from participating

Manju Yadav, Indore vs. ITO-1(2), Indore

The appeal of the assessee is allowed

ITA 469/IND/2025[2016-17]Status: DisposedITAT Indore13 Jan 2026AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 142(1)Section 144Section 147Section 271(1)(b)

section 142(1) of the Act dated 25.01.2024 was never served upon her either through e-mail or by post and, therefore, there was reasonable cause for the alleged non-compliance. The assessee also submitted that the assessment order itself had been challenged in appeal before the learned ... section 142(1) of the Act was duly served on the assessee through the e-filing portal, that the assessee failed to demonstrate any reasonable cause for non-compliance, and that the pendency of the appeal against the assessment order did not affect the validity of the penalty proceedings

Dr. R.M. Lohia Institute of Medical Sciences, Lucknow vs. NFAC, Delhi

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

ITA 519/LKW/2025[201-2020]Status: DisposedITAT Lucknow13 Jan 2026

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

For Appellant: Sh. B.P. Yadav, AdvFor Respondent: Sh. Neeraj Kumar, CIT DR
Section 10Section 139(1)Section 147Section 148Section 194CSection 194J

order dated 27.08.2024 dismissed the appeal in limine by observing that "I am of the view that in the absence of existence of reasonable cause and also in the absence of proper evidence, the appeal filed by the assessee late by 20 days, the delay is not condonable. Hence

Mahesh Krishnarao Dhavan, Pune vs. Income Tax Officer, Ward 10(1), Pune

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

ITA 2977/PUN/2025[2016-17]Status: DisposedITAT Pune13 Jan 2026AY 2016-17

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2977/Pun/2025 Assessment Year : 2016-17

For Respondent: Assessee by None
Section 143(3)Section 250

Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987) 2 SCC 107) I find that due to ‘reasonable cause’ assessee failed to file the appeal within the time limit specified under the Act. I therefore condone the delay of 582 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 Ground No.1 raised by the assessee is allowed for statistical purposes. 8. Since by way of Ground

Sangitadevi Kishorekumar Mundra, Ichalkaranji vs. Income Tax Officer, Kolhapur

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

ITA 2762/PUN/2025[2020-21]Status: DisposedITAT Pune13 Jan 2026AY 2020-21

Bench: Dr. Manish Borad & Ms. Astha Chandra

For Appellant: Shri Pramod S Shingte, ARFor Respondent: Shri Aviyogi Ambadkar, Addl.CIT
Section 147Section 148Section 250Section 250(6)

Suresh Chandra Premraj Kasat on 23.12.2024 who was looking after the taxation matters of the assessee. We find that this is a reasonable cause because for such taxation matters the assessee(s) are dependent on the Tax Consultant and it is not so easy to locate a new Tax Consultant ... assessee is also directed to remain vigilant and 4 ITA.No.2762/PUN/2025 (Sangitadevi Kishorekumar Mundra) not to take unnecessary adjournments unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. 7. In the result, appeal of the Assessee is allowed for statistical

Venkateshwara B V Biocorp Private Limited, Pune vs. Circle 12, Pune

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

ITA 2759/PUN/2025[2022-2023]Status: DisposedITAT Pune13 Jan 2026AY 2022-2023

Bench: Dr. Manish Borad & Ms. Astha Chandra

For Appellant: Shri Nikhil S Pathak, ARFor Respondent: Shri Aviyogi Ambadkar, Addl.CIT
Section 143(1)Section 143(1)(a)Section 250Section 250(6)

appeal. He also submitted that the delay is only one day and that too on account of technical glitches, but in spite of reasonable cause mentioned in the application for condonation of delay filed before the Ld.CIT(A), delay in filing the appeal has not been condoned and the appeal ... whereas the assessee demonstrated that delay is only one day, that also due to technical glitches in e-filing portal. We find that reasonable cause prevented the assessee from filing the appeal before the Ld.CIT(A) within the prescribed time limit and that the delay is not intentional and therefore

Sachin Manilal Shah, Panvel vs. ITO Ward 2, Panvel

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

ITA 1925/PUN/2024[2013-14]Status: DisposedITAT Pune13 Jan 2026AY 2013-14

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1925/Pun/2024 धििाारण वर्ा / Assessment Year: 2013-14 Sachin Manilal Shah, Vs Ito Ward 2, D1/2, 1St Floor, Shiv Panvel Complex Municipal Office Road, Near Gokhale Hall, Panvel-410206 Maharashtra Pan-Atcps2791R Appellant Respondent

For Appellant: Shri Kaushik Makwana and Shri Sanjay KabraFor Respondent: Shri Aviyogi Ambadkar
Section 144Section 147Section 148Section 250

hearing shall be granted to the assessee. Assessee is also directed to 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. 5 7. In the result appeal of the assessee is allowed

Umashanker Shiwaprasad Modi, Thane vs. Circle 19(3), Mumbai

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

ITA 5074/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Jan 2026AY 2018-19

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2018-19 Mr. Umashanker Modi Income Tax Department, Office No. D, 12Th Floor, Mbc Park, National Faceless Appeals Vs. D Building, Near Hypercity, Centre (Nfac), Delhi. Ghodbunder Road, Kasarvadavali, Thane West, Thane- 400615. Pan No. Aabpm 8785 D Appellant Respondent

For Appellant: Mr. Vivek Perampurna, CIT-DRFor Respondent: Mr. Fenil Bhatt
Section 144Section 250Section 68

erred in law and on facts in passing the order under section 250 of the Income Tax Act, 1961 without considering the genuine and reasonable cause for non-compliance during appellate proceedings. Umashankar Shiwaprasad Modi 2 2. That the Learned Assessing Officer erred in law and on facts

Dharmendry Sanjay Bhatta, Rajkot vs. ITO, Ward-1(1)(1), Rajkot

In the result, the appeal of the assessee is allowed

ITA 620/RJT/2025[2017-18]Status: DisposedITAT Rajkot12 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकरअपील सं/ .Ita No. 620/Rjt/2025 िनधा"रण वष"/Assessment Year : 2017-18 बनाम/ Shri Dharmendry Bhatta. Income Tax Officer, Ward 1(1)1 Deep, 41- Anant Nagar Society, Aaykar Bhawan, Race Course Ring Vs Kalawad Road, Road, Rajkot -360005 Rajkot - 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aebpb0458E (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Anadi Dixit, Ld. Sr. DR
Section 142(1)Section 147Section 148Section 250Section 271A(1)(d)Section 272ASection 272A(1)(d)

held that the assessee has failed to comply with the statutory notices u/s. 142(1) of the Act on various date without any reasonable cause. Therefore, the AO was of the view that as per the provisions of sec.272A(1)(d) of the I.T. Act penalty of Rs.10

Plutus Infrastructure Ltd, Patna vs. ITO, Ward-2(2), Patna

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

ITA 30/PAT/2025[2015-16]Status: DisposedITAT Patna12 Jan 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.30/Pat/2025 Assessment Year: 2015-16 Plutus Infrastructure Ltd.………………. …………………....Appellant 310, N P Centre, New Dak Bunglow Road, Patna- 800001.. [Pan: Aadcp2152Q] Vs. Ito, Ward-2(2), Patna……..…..……………..………………….…..... Respondent Appearances By: Shri D. V. Pathy, Sr. Adv. Appeared On Behalf Of The Appellant. None Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 07, 2026 Date Of Pronouncing The Order : January 12, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 29.02.2024 Passed By The Nfac, Delhi U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is A Company Engaged In The Business Of Real Estate Development & Construction. For The Assessment Year 2015–16, The Assessee Filed Its Return Of Income Declaring A Total Income Of ₹83,028. During The Course Of Assessment Proceedings, The Assessing Officer Estimated The Net Profit At The Rate Of 8% On Undisclosed Sales & Accordingly Made An Addition Of ₹17,71,120. In Addition Thereto, An Addition Of ₹5,60,000 Was Made

Section 250Section 43C

condonation of delay, explaining the reasons for such delay. After considering the submissions and the reasons stated, we are satisfied that there existed a reasonable cause preventing the assessee from filing the appeal within the prescribed time. Accordingly, the delay of 303 days is condoned. 5. It was submitted that

Amit Singh, Chandigarh vs. Addl.CIT-Range-5, Chandigarh

The appeal stand allowed

ITA 238/CHANDI/2024[2010-11]Status: DisposedITAT Chandigarh12 Jan 2026AY 2010-11

Bench: SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Ajay Chauhan Singh (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 269SSection 271DSection 271ESection 273B

assessee earned business income. The assessee was to demonstrate bona-fide reasons for taking such loans in order to consider the applicability of Sec.273B (reasonable cause) while assailing impugned penalties. No such cause was established. Accordingly, both the penalties were upheld. Aggrieved, the assessee is in further appeal before Tribunal ... Therefore, the assessee, in my considered opinion, would be covered under second proviso. 6. Proceeding further, the assessee would succeed on the plea of reasonable cause also since it is the first year of start of business. The nature of business i.e., construction and building material would involve cash transactions

Amit Singh, Chandigarh vs. Addl.CIT-Range-5, Chandigarh

The appeal stand allowed

ITA 237/CHANDI/2024[2010-11]Status: DisposedITAT Chandigarh12 Jan 2026AY 2010-11

Bench: SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Ajay Chauhan Singh (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 269SSection 271DSection 271ESection 273B

assessee earned business income. The assessee was to demonstrate bona-fide reasons for taking such loans in order to consider the applicability of Sec.273B (reasonable cause) while assailing impugned penalties. No such cause was established. Accordingly, both the penalties were upheld. Aggrieved, the assessee is in further appeal before Tribunal ... Therefore, the assessee, in my considered opinion, would be covered under second proviso. 6. Proceeding further, the assessee would succeed on the plea of reasonable cause also since it is the first year of start of business. The nature of business i.e., construction and building material would involve cash transactions