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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

Vinod (Ratan) Suhalka, Udaipur vs. ACIT, Central Circle-1, Udaipur

In the result, the appeals of the assessee are allowed

ITA 241/JODH/2019[2007-08]Status: PendingITAT Jodhpur05 Jan 2023AY 2007-08

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

Section 132Section 132(4)Section 153ASection 271(1)(c)

assessment year 2007-08, it appears to me that you – Section 271(1) read with Section 274 271(1)(a) Have without reasonable cause failed to furnish the return of income which you were required to furnish u/s 139(1) or by a notice given under section ... Income Tax, 1961 or have without reasonable cause failed to furnish it within the time allowed and in the manner requiuired by said section 139(1) by such notice. 271(1)(b) Have without reasonable cause failed to comply with a notice u/s 142(1)/ 143(2) of the Income

Simple Singh, Meerut vs. ITO Ward-1(2)(5), Meerut

In the result, the appeal of the assessee is allowed

ITA 1367/DEL/2022[2011-12]Status: DisposedITAT Delhi05 Jan 2023AY 2011-12

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia[Assessment Year : 2011-12] Simple Singh, Vs Ito, Kartar Singh & Co., 86, Bank Street, Ward-1(2)(5), Meerut Cantt., Meerut, Meerut. Uttar Rpadesh-250001. Pan-Awmps7877F Appellant Respondent Appellant By Shri R.P.Narang, Adv. Respondent By Shri Abhishek Kumar, Sr.Dr Date Of Hearing 21.12.2022 Date Of Pronouncement 05.01.2023

Section 142(1)Section 144Section 147Section 148Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER & SHRI PRADIP KUMAR

Chandrakant Bhagwanji Popat, Surat vs. Dy. Commissioner of Income Tax, Cir. 1(3), Surat

In the result, grounds of appeal raised by the assessee is allowed

ITA 265/SRT/2022[2015-16]Status: HeardITAT Surat02 Jan 2023AY 2015-16

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) Chandrakant Bhagwanji Popat, D.C.I.T., 54, Dev Deep Society, Circle-1(3), Vs. Ichchhanath Road, Surat. Surat. Pan No. Abnpp 1088 R Appellant/ Assessee Respondent/ Revenue

Section 112Section 250(6)Section 254(1)Section 54F

being heard to the appellant. 3.1 That the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi has failed to appreciate that there was reasonable cause for the appellant for not causing appearance on the dates fixed for hearing and as such disposal of the appeal without granting fair, meaningful

Ramakrishna Murali, Bangalore vs. Income Tax Officer, Ward-6(3)(1), Bangalore

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

ITA 975/BANG/2022[2012-13]Status: DisposedITAT Bangalore30 Dec 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri Raghavendra Chakravarthy, A.RFor Respondent: Shri K.R. Narayana, D.R
Section 143(3)Section 250Section 271D

argument on merit of the issue before AO. At the time of hearing, the Bench asked the Ld AR whether assessee has any reasonable cause to receive the cash advances otherwise than by cheque or demand draft as enumerated in section 273B of the Act. In reply ... this is not stipulated in the provisions of section 273B of the Act. Accordingly, in our opinion, there is no reasonable cause so exist at the time of taking this impugned amount of cash loan from various parties otherwise than by crossed cheque or demand draft. In view

Mamta Mehta, Mumbai vs. Income Tax Officer Ward 31(2)(3), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 1237/MUM/2022[2011-12]Status: DisposedITAT Mumbai29 Dec 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadale

For Appellant: Mr. Bhupendra Shah.ARFor Respondent: Mr. Tejinder Pal Singh Anand.DR
Section 10(38)Section 143(1)Section 143(3)Section 148Section 271BSection 274Section 44A

under the bonafide belief and therefore no penalty can be levied. Further the Ld.AR mentioned that it is not a wanton act and the reasonable cause is explained and supported the submissions with the judicial decisions ITA No. 1237/Mum/2022 & 1861/Mum/2021 Mamta Sundeep Mehta, Mumbai. and factual paper book and prayed ... included for the purpose of determining the obligation of Tax Audit under section 44AB of the Act and same constitute a reasonable cause for not getting the books of accounts audited U/sec44AB of the Act and the default committed in not getting the Audit report is without any malafide intentions

Bharati Rani Saha, Kolkata vs. I.T.O., Ward - 61(3), Kolkata

The appeals of the assessee are allowed for statistical purposes

ITA 423/KOL/2022[2012-2013]Status: DisposedITAT Kolkata23 Dec 2022AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 249Section 253Section 3Section 5

then there is substantial delay at the part of the assessee but we are of the view that the delay is for sufficient and reasonable cause. Moreover, making the appeal time-barred has not been used by the assessee as a tactics to avoid the litigation with the Revenue because

Bharati Rani Saha, Kolkata vs. I.T.O., Ward-61(3), Kolkata

The appeals of the assessee are allowed for statistical purposes

ITA 422/KOL/2022[2011-2012]Status: DisposedITAT Kolkata23 Dec 2022AY 2011-2012

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 249Section 253Section 3Section 5

then there is substantial delay at the part of the assessee but we are of the view that the delay is for sufficient and reasonable cause. Moreover, making the appeal time-barred has not been used by the assessee as a tactics to avoid the litigation with the Revenue because

Bharati Rani Saha, Kolkata vs. I.T.O., Ward - 61(3), Kolkata

The appeals of the assessee are allowed for statistical purposes

ITA 421/KOL/2022[2010-2011]Status: DisposedITAT Kolkata23 Dec 2022AY 2010-2011

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 249Section 253Section 3Section 5

then there is substantial delay at the part of the assessee but we are of the view that the delay is for sufficient and reasonable cause. Moreover, making the appeal time-barred has not been used by the assessee as a tactics to avoid the litigation with the Revenue because

DCIT 3(3)(1), Mumbai vs. M/S Toshiba Johnson Elevators India Pvt Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 488/MUM/2022[2016-17]Status: DisposedITAT Mumbai23 Dec 2022AY 2016-17
For Appellant: Sh. Akhtar Ansari, Sr. DRFor Respondent: Sh. M.P. Lohia, CA &
Section 12ASection 138Section 250Section 271GSection 273BSection 92C

supporting documentation which was mandatorily to be provided by the assessee as obligatory compliance of the Rules has been violated even though the reasonable cause has not been established to invoke section 273B of the IT Act and when the Transfer Pricing Study Report submitted by assessee was nothing

Vijayalaxmi Metals Pvt. Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre, Delhi

ITA 1763/MUM/2022[2015-16]Status: DisposedITAT Mumbai22 Dec 2022AY 2015-16

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2015-16 & Assessment Year: 2015-16

For Appellant: NoneFor Respondent: Shri Nimesh Yadav, D.R
Section 269SSection 269TSection 271DSection 271E

Commissioner (Appeals) - NFAC Delhi has erred both on facts and in law in confirming the penalty despite the fact that there being a reasonable cause' for non-compliance with provisions of section 269S of the Income Tax Act, 1961. 4. On the facts and circumstances of the case

Vijayalaxmi Metals Pvt. Ltd, Mumbai vs. Commissioner of Income Tax (Appeals ) NFAC, Delhi

ITA 1750/MUM/2022[2015-16]Status: DisposedITAT Mumbai22 Dec 2022AY 2015-16

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2015-16 & Assessment Year: 2015-16

For Appellant: NoneFor Respondent: Shri Nimesh Yadav, D.R
Section 269SSection 269TSection 271DSection 271E

Commissioner (Appeals) - NFAC Delhi has erred both on facts and in law in confirming the penalty despite the fact that there being a reasonable cause' for non-compliance with provisions of section 269S of the Income Tax Act, 1961. 4. On the facts and circumstances of the case

Visa Sales Pvt. Ltd., Kolkata vs. A.O. Ward 1(3), Kolkata

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

ITA 526/KOL/2021[2011-12]Status: DisposedITAT Kolkata21 Dec 2022AY 2011-12

Bench: Shri Rajpal Yadav, Vice- & Shri Manish Boradi.T.A. No.526/Kol/2021 Assessment Year: 2011-12 Visa Sales Pvt. Ltd........….……………………....................……….……Appellant 12, Waterloo Street, Kolkata-700069. [Pan: Aadcv1161H] Vs. A.O, Ward-1(3), Kolkata……..….…..….........……........……...…..…..Respondent Appearances By: Shri Narayan Gupta, Ar, Appeared On Behalf Of The Appellant. Smt. Ranu Biswas, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 09, 2022 Date Of Pronouncing The Order : December 21, 2022 Order Per Manish Borad: This Appeal Filed By The Assessee Pertaining To Assessment Year 2011-12 Is Directed Against The Order Of The Ld. Commissioner Of Income Tax(Appeals)-19, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Dated 06.03.2018 Is Arising Out Of The Order U/S 143(3) Of The Act Dated 29.03.2014 Passed By Ito, Ward-1(3), Kolkata. 2. The Registry Has Informed That This Appeal Is Time Barred By 968 Days. On Going Through The Condonation Application In The Form Of Affidavit & After Hearing Both The Parties, We Find That This Delay Is Accountable For Two Reasons. Firstly, The Impugned Order Of The Cit(A) Is Dated 06.03.2018 & The Assessee Has Not Received The Order On Time. Secondly, The Period Of Delay Occurred On Account Of Lockdown In The State Due To Outbreak Of Covid-19. In View Of The Reasons Stated In The Affidavit For Condonation Of Delay & Also The Extension Of Limitation Period By Hon’Ble Supreme Court In Suo Moto Writ Petition (Civil) No.3 Of 2020 Dated 10.01.2022 By Which The Period From 15.03.2020 To 28.02.2022 Has Been Directed To Be Excluded For The Purpose Of Limitation & A Further Period Of 90 Days Has Been Granted For Providing The Limitation From 01.03.2022, We, Therefore, Condone The Delay In Filing This Appeal & Admit The Same For Adjudication.

Section 143(3)Section 68

provided sufficient opportunity of being heard. We further direct the assessee to remain compliant and not to take adjournment unless and otherwise required for reasonable cause and if assessee fails to appear on the first two dates of hearing without giving any reasonable cause then

M/S Kotalipara Development Society, Barasat vs. I.T.O.(Exemption), Ward-1(4), Kolkata

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

ITA 164/KOL/2020[2013-14]Status: DisposedITAT Kolkata21 Dec 2022AY 2013-14

Bench: Dr. Manish Boradi.T.A No.164/Kol/2020 Assessment Year: 2013-14 M/S Kotalipara Development Society....................................................…… …. Appellant Pioneer Para, Noapara, P.O. Barasat, North 24 Parganas, W.B. 700124. [Pan:Aaaak3272B] Vs. Ito(Exemption), Ward-1(4), Kolkata........................................................….. Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Vijay Kumar, Addl. Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 13, 2022 Date Of Pronouncing The Order : December 21, 2022 आदेश / Order

Section 143(3)Section 2(15)Section 250

provided sufficient opportunity of being heard. We, also, direct the assessee to remain compliant and not to take adjournment unless and otherwise required for reasonable cause and if assessee fails to appear on the first two dates of hearing without giving any reasonable cause then

M. Vijayakumar(Rep by His Wife S. Yasodha), Erode vs. ITO, Intnl Taxaton Ward, Coimbatore

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

ITA 689/CHNY/2022[2017-18]Status: DisposedITAT Chennai21 Dec 2022AY 2017-18

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.: 689/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Shri M. Vijayakumar, The Income Tax Officer, Rep. By His Wife Smt. S.Yasodha, Vs. International Taxation 26, Kuttakkattuvalasu, Elumathur, Ward, Erode – 638 104. Coimbatore. Pan : Ajbpv 0551B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई क" तार"ख/Date Of Hearing : 19.12.2022 घोषणा क" तार"ख/Date Of Pronouncement : 21.12.2022 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai In Ita No.101/Cit(A)-16/2019-20 Dated 13.07.2022. The Assessment Was Framed By The Income Tax Officer, International Taxation Ward, Coimbatore For The Assessment Year 2017-18 U/S.143(3) Of The Income Tax Act, 1961, (Hereinafter ‘The Act’) Vide Order Dated 25.12.2019. 2. The Only Issue In This Appeal Is As Regard To The Order Of Cit(A) Confirming The Action Of Ao In Making Addition Of Rs.8 Lakhs As Unexplained Money U/S.69A Of The Act.

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 143(3)Section 69A

before the AO or before the CIT(A) at the first instance and for not filing before the lower authorities, the assessee has no reasonable cause and there is no reason or occasion to file before Tribunal for the first time. He aggressively took his stand that this should

Burdwan Co-Operative Agriculture and Rural Development Bank Limited, Burdwan vs. ITO, Ward-1(1), Burdwan

In the result, both the appeals of the assessee are allowed

ITA 205/KOL/2022[2015-16]Status: DisposedITAT Kolkata20 Dec 2022AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. Nos. 204 & 205/Kol/2022 Assessment Year: 2015-2016 Burdwan Cooperative Agriculture & Rural Development Bank Limited,........................Appellant Old Court Compound, Burdwan-713101, W.B. [Pan: Aacab0468Q] -Vs.- Income Tax Officer,.................................Respondent Ward-1(1), Burdwan, Aayakar Bhawan, Court Compound, Burdwan-713101 Appearances By: Shri Palas Chattopadhyay, Fca, Appeared On Behalf Of The Assessee Shri Biswanath Das, Cit (D.R.), Appeared On Behalf Of The Revenue

Section 139(4)Section 271BSection 44A

That this delay having taken place unintentionally and I having been prevented by sufficient and reasonable cause in filing Tax Audit Reprt and the return of income within time. On the above facts, there was no malafide intention behind not having filed the Tax Audit Report and the return

Burdwan Co-Operative Agriculture and Rural Development Bank Limited, Burdwan vs. ITO, Ward-1(1), Burdwan

In the result, both the appeals of the assessee are allowed

ITA 204/KOL/2022[2015-16]Status: DisposedITAT Kolkata20 Dec 2022AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. Nos. 204 & 205/Kol/2022 Assessment Year: 2015-2016 Burdwan Cooperative Agriculture & Rural Development Bank Limited,........................Appellant Old Court Compound, Burdwan-713101, W.B. [Pan: Aacab0468Q] -Vs.- Income Tax Officer,.................................Respondent Ward-1(1), Burdwan, Aayakar Bhawan, Court Compound, Burdwan-713101 Appearances By: Shri Palas Chattopadhyay, Fca, Appeared On Behalf Of The Assessee Shri Biswanath Das, Cit (D.R.), Appeared On Behalf Of The Revenue

Section 139(4)Section 271BSection 44A

That this delay having taken place unintentionally and I having been prevented by sufficient and reasonable cause in filing Tax Audit Reprt and the return of income within time. On the above facts, there was no malafide intention behind not having filed the Tax Audit Report and the return

Manish Kumudchandra Metha, Mumbai vs. Income Tax Officer-19(2)(3), Mumbai

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

ITA 2407/MUM/2022[2011-2012]Status: DisposedITAT Mumbai20 Dec 2022AY 2011-2012

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.2407/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2011-12) Manish Kumudchandra Mehta बिधम/ Vs. Acit, Circle-19(2) 7, Sudha, 2Nd Floor, Patel Compound, 14, Hanvant Bhavan, 80E, Sea Road, Napeansea Road, Mumbai-400006. Mumbai-400036. आयकरअपीलसं/ I.T.A. No.2409/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2013-14) Manish Kumudchandra Mehta बिधम/ Vs. Income Tax Officer- 19(2)(3) 7, Sudha, 2Nd Floor, Patel Compound, Matru Mandir, 2Nd Floor, Sea Road, Grant Road, Mumbai-400036. Mumbai- 400007. स्थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aadpm9184G (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: None Revenue By: Smt. Mahita Nair (Sr. Ar. Cit) सुनवाईकीतारीख / Date Of Hearing: 17/11/2022 घोषणाकीतारीख /Date Of Pronouncement: 20/12/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against Order Of The Ld. Cit(A) Dated 27-07-2022 For A.Y. 2011-12 & Ay. 2013-14. 2. None Appeared For The Assessee. However, Having Perused The Grounds Of Appeal Raised By The Assessee, We Note That The Main Grievance Of The Assessee In

For Appellant: NoneFor Respondent: Smt. Mahita Nair (Sr. Ar. CIT)
Section 143(3)Section 249(2)

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI GAGAN GOYAL, AM

Deputy Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Mahavir Build Estate Pvt Ltd, Mumbai

In the result, appeal preferred by the Revenue is dismissed

ITA 1405/MUM/2022[2009-2010]Status: DisposedITAT Mumbai20 Dec 2022AY 2009-2010
For Appellant: Shri Gunajjan KakkadFor Respondent: Shri Nishant Somaiya
Section 132Section 143(3)Section 147Section 250Section 269SSection 271DSection 273B

justified in deleting the penalty levied u/s. 271D of the Act since the assessee has not shown the reasonable cause w/s. 273B of the Act for entering into such transactions through journal entries? 2. On the facts and in the circumstances of the case ... erred in deleting the penalty without giving a finding on transaction to transaction basis in the given case for existence of reasonable cause u/s. 273B which led to the exigency of contravention of provisions of 269SS as the fact of each transaction need independent verification?" 3. On the facts

Sunny Park Apartment Owners Association, Kolkata vs. CIT(A), Kolkata

In the result, both the appeals filed by the assessee are allowed

ITA 567/KOL/2022[2015-2016]Status: DisposedITAT Kolkata19 Dec 2022AY 2015-2016

Bench: Dr. Manish Borad

Section 250

I.T.A. Nos.: 566 & 567/Kol/2022 Assessment Years: 2014-15 & 2015-16 Sunny Park Apartment Owners Association. and am satisfied that the assessee was prevented for reasonable cause in filing the instant appeals within statutory time limit. I, therefore, condone the delay and admit the appeals for adjudication. 3. The assessee

Sunny Park Apartment Owners Association, Kolkata vs. NFAC, Delhi

In the result, both the appeals filed by the assessee are allowed

ITA 566/KOL/2022[2014-2015]Status: DisposedITAT Kolkata19 Dec 2022AY 2014-2015

Bench: Dr. Manish Borad

Section 250

I.T.A. Nos.: 566 & 567/Kol/2022 Assessment Years: 2014-15 & 2015-16 Sunny Park Apartment Owners Association. and am satisfied that the assessee was prevented for reasonable cause in filing the instant appeals within statutory time limit. I, therefore, condone the delay and admit the appeals for adjudication. 3. The assessee