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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

Veera Reddy Posham, Nalgonda vs. ACIT, Central Circle-1(1), Hyderabad

ITA 1829/HYD/2025[2020-21]Status: DisposedITAT Hyderabad13 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita.Nos.1829 & 1830/Hyd/2025

For Appellant: -None-For Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 132Section 143(3)Section 147Section 148Section 234FSection 250(6)Section 270ASection 80CSection 80C(2)(xvii)

erred in dismissing the appeal ex parte, ignoring that sufficient and reasonable opportunities were not effectively granted or that the appellant was prevented by reasonable cause from compliance. • The learned CIT(A) erred in not adjudicating the appeal on merits despite the fact that documentary evidence was available/could have been

Dandeboina Ramesh, Warangal vs. ITO, Ward-(1), Warangal

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

ITA 1661/HYD/2025[2015-16]Status: DisposedITAT Hyderabad13 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Section 115Section 139Section 144Section 147Section 148Section 148ASection 149Section 69A

No.1661/Hyd/2025 Dandeboina Ramesh vs. ITO 6. Per contra, the Learned Departmental Representative (“Ld. DR’) submitted that the assessee failed to show any reasonable cause for the delay in filing the appeal before the Ld. CIT(A). The Ld. DR submitted that the Ld. CIT(A) has rightly refused to condone

R Vinothkumar, Cuddalore vs. ITO, Cuddalore

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

ITA 3361/CHNY/2025[2015-16]Status: DisposedITAT Chennai13 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Mr. S. Aadhi Sesha Kumar, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 147Section 148Section 69A

appreciate that the assessee could have derived no benefit by not responding to the notices issued on the assessee and the assessee had reasonable cause for not responding to the notices issued by the ld.CIT(A) and hence the assessee could not submit the written submission and valid evidence before

Ramesh Lalawat, Vashi Mumbai vs. Income Tax Officer Ward 28(2)(1), Navi Mumbai

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

ITA 8838/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Ramesh Lalawat Income Tax Officer, Room No 102, Goma Sadan Ward 28(2)(1), Plot No 400, Mumbai Nr Cisf, Juhu Gaon Vs. Sector No. 11, Vashi, Navi Mumbai - 400703 (Pan: Aeepl2218K) (Appellant) (Respondent) Present For: Assessee : Shri Ajay R. Singh, Advocate Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 09.03.2026 Date Of Pronouncement : 13.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1074653077(1), Dated 18.03.2025, Passed Against The Assessment Order By Mum-W-(272)(91), U/S. 147 R.W.S. 144 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 15.09.2023, For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under:

For Appellant: Shri Ajay R. Singh, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 147Section 249Section 249(2)Section 3Section 5

specifically due to non-receipts of assessment order. Thus the Ld. CIT (A) failed to appreciate that the appellant had demonstrated the sufficient and reasonable cause for the delay which was neither found to be false or misleading. Therefore, the dismissal of appeal on the ground of delay

Nathan Anil Rao, Mumbai vs. The ITO -Circle 23(1), Mumbai

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

ITA 8666/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Vijaykumar Soni, CIT DRFor Respondent: Shri Nikhil Tiwari
Section 143(2)Section 68Section 69

rejecting the Appellant's short adjournment of being heard to the Appellant by rejecting the Appellant's short adjournment request and not appreciating the reasonable cause for the adjournment request and not appreciating the reasonable cause for the adjournment request and not appreciating the reasonable cause for the adjournment provided

Bharat Thakarshi Mamania, Mumbai vs. ITO 22(1)(6), Mumbai

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

ITA 8510/MUM/2025[2012-2013]Status: DisposedITAT Mumbai13 Mar 2026AY 2012-2013

Bench: Smt. Beena Pillai ()

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 69C

intention on behalf of assessee for not filing the present appeals before this Tribunal. 4.1. In our view, the assessee has made out a reasonable cause for the delay that is caused in filing the present appeal before this Tribunal. Nothing to establish any contrary intention has been filed

Vijay Kumar, Karnal vs. Income Tax Officer, Karnal

In the result, the appeal of the assessee is allowed

ITA 6652/DEL/2025[2019-20]Status: DisposedITAT Delhi13 Mar 2026AY 2019-20

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Vs Vijay Kumar, Ito, H.No. 841, Sector-9, Urban Aaykar Bhawan, Estate, Karnal, Sector-12, Karnal, Haryana-132001 Haryana [Pan: Ashpk3257A) (Respondent) (Appellant)

Section 142(1)Section 144Section 148Section 148ASection 250Section 271ASection 272A(1)(d)Section 69A

statutory notices as he was not aware about government ITD portal and even prior to filer not inform about the notices and has a reasonable cause for not attending the assessment proceedings before the AO who has passed even order u/s. 144/147/144B of the Act. 4. Under the facts ... statutory notices as he was not aware about government ITD portal and even prior to filer not inform about the notices and has a reasonable cause for not attending the assessment proceedings before the AO who has passed even order u/s. 144/147/144B of the Act. Further it was the contention

Jai Kissan Foods, Kashipur vs. Ward-2(2)(1) Kashipur, Kashipur

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

ITA 38/DDN/2026[2022-23]Status: DisposedITAT Dehradun12 Mar 2026AY 2022-23

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2022-23] Jai Kisan Foods Vs Ward-2(2)(1) Village Nijhraudham Singh Kashipur Nagar, Kashipur, Uttarakhand Uttarakhand Pan-Aaofj0629G Appellant Respondent Appellant By Shri Soumya Bumb, Ca Respondent By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 11.03.2026 Date Of Pronouncement 12.03.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 16.12.2025 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-13, Mumbai [“Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Against The Rectification Order Dated 15.10.2024 Passed U/S 154 Of The Act Pertaining To Assessment Year 2022-23. 2. Heard The Contentions Of Both The Parties & Perused The Material Available On Record. Ld. Cit(A) Dismissed The Appeal Of The Assessee By Not Condoning The Delay Of 267 Days. From The Perusal Of The Appeal Memo Filed Before Ld. Cit(A) In Form No. 35 As Well As Order Of Ld. Cit(A), It Is Observed That The Assessee Has Not Tendered Any Valid Explanation For Delay In Filing The Appeal.

Section 154Section 250

tendered any valid explanation for delay in filing the appeal. 3. Considering the overall facts and in our considered view, sufficient and reasonable cause for delay in filing the appeal has not been explained before the Ld. CIT(A). Therefore, we deem it fit to restore the issue

Pal Mineral Industries (P) Limited, Haldwani vs. Dc/ACIT, Central Circle, Haldwani

ITA 106/DDN/2025[2013-2014]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-2014

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

106/DDN/2024 the appeal could not be filed with the limitation period. We find that the reasons stated is having genuine and reasonable cause thus, the delay in filing the appeal by 08 days is condoned. 3. Ld.AR for the assessee filed an application for admission of additional grounds of appeal

Pal Mineral Industries (P) Limited, Haldwani vs. Dc/ACIT, Central Circle, Haldwani

ITA 105/DDN/2025[2014-2015]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-2015

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

106/DDN/2024 the appeal could not be filed with the limitation period. We find that the reasons stated is having genuine and reasonable cause thus, the delay in filing the appeal by 08 days is condoned. 3. Ld.AR for the assessee filed an application for admission of additional grounds of appeal

Kshatriya Vikas Parisad Gujarat, Ahmedabad vs. The CIT(Exemption), Ahmedabad

Accordingly, in the absence of any satisfactory explanation for the inordinate delay of 1109 days, the application filed by the assessee for condonation of delay is dismissed

ITA 2485/AHD/2025[NA]Status: DisposedITAT Ahmedabad12 Mar 2026

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Ms. Mauli Shah, CAFor Respondent: Shri Alpesh Parmar, CIT DR

that inordinate delay cannot be condoned merely on the basis of routine explanations and that the party seeking condonation must show bona fide and reasonable cause for the delay. The Hon’ble Supreme Court observed that courts cannot condone delay in a mechanical manner where the explanation furnished is casual ... party is negligent or lacking in bona fides. 11. In the present case, the assessee has failed to demonstrate any sufficient or reasonable cause explaining the extraordinary delay of 1109 days in filing the appeal. The explanation furnished is vague, unsupported by any documentary evidence and does not justify

Air Wind Green Energy Limited, Bhavnagar vs. The Dy.CIT, Circle-1, Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 2435/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri C Dharani Nath, Sr. DR
Section 142(1)Section 272ASection 272A(1)(d)Section 273BSection 274

contrary to principle of natural justice and therefore liable to be quashed. The appellant was prevented by sufficient and reasonable caused u/s. 273B of the Income Tax Act from filing the appeal within statutory time period. The rejection of delay condonation appeal is violation of principle of natural justice. Hence ... satisfied with the explanation furnished by the assessee and observed that the assessee had failed to comply with the statutory notices without reasonable cause. Accordingly, invoking the provisions of section 272A(1)(d) of the Act, the Assessing Officer held that the assessee had defaulted in complying with the statutory

Mr. Yogesh Santosh Gulvi, Mumbai vs. Income Tax Office Ward 1(4), Mumbai

Accordingly Ground No.1 to 14 raised by the Assessee are allowed for statistical purpose

ITA 554/MUM/2026[2012-13]Status: DisposedITAT Mumbai12 Mar 2026AY 2012-13

Bench: this tribunal on the following grounds as under:- 3. That on the facts and in the circumstances of the case and in law, the learned CIT(A) erred in dismissing the appeal without deciding the case on merits and without appreciating the facts submitted in the Grounds of Appeal.

For Appellant: None
Section 144Section 147Section 69A

documentary evidence related to the source of cash deposit. 6. That the learned CIT(A) failed to consider that the appellant was prevented by reasonable cause from submitting replies due to unavoidable circumstances, therefore the appeal should not have been dismissed in limine. 7. Without prejudice to the above

St. Thomas High School, Mumbai vs. ITO Exemption Ward 2(3), Mumbai

In the result, the appeal by the assessee is dismissed as withdrawn

ITA 6931/MUM/2025[2023-24]Status: DisposedITAT Mumbai12 Mar 2026AY 2023-24

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Ketan PatelFor Respondent: Shri Hemanshu Joshi SR. DR
Section 11Section 119(2)(b)Section 13(10)Section 250

learned Commissioner of Income Tax (Exemption) Mumbai, in the meantime, has accepted the said condonation petition and being convinced that the Appellant Trust had reasonable cause for the delay in filing of Audit Report in Form 10B for Assessment Year 2023-24, he has condoned the delay vide order dated

Ravipati Radha Bai, Hyderabad vs. ITO, Ward 7(1), Hyderabad

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

ITA 2022/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.2022/Hyd/2025 Assessment Year 2017-2018 Ravipati Radha Bai [[ The Income Tax Officer, Hyderabad – 500 028. Ward-7(1), Vs. Telangana. Hyderabad – 500 084. Pan Aaihr4276B (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri H Srinivasulu, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 05.03.2026 घोषणा की तारीख/Pronouncement: 11.03.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri H Srinivasulu, AdvocateFor Respondent: MS Reema Yadav, Sr. AR
Section 144Section 250

relative who expired in the month of June 2025. The learned DR has thus submitted that the assessee has not explained the reasonable cause in filing the appeal with abnormal delay of 270 days. 4. We have considered the rival submissions as well as carefully perused the reasons explained

Mahesh Kenchanagundu, Nandyala vs. ITO., Ward-1, Nandyal

ITA 1611/HYD/2025[2015-14]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita.No.1611/Hyd/2025

Section 147Section 269SSection 271DSection 273B

down in the following decisions: CIT v. Panchsheel Owners Associations (2017) 395 ITR 380 (Guj. HC) Penalty deleted where cash loan was genuine and reasonable cause for acceptance proved. Narendrakumar Chunilal Soni vs. JCIT, ITAT Ahmedabad Penalty deleted for genuine cash loans from agriculturists with no taxable income. Maa Khodiyar ... Bench ITA No. 22/Coch/2012 Cash loans between agriculturists not hit by Section 269SS, hence penalty under Section 271D not sustainable. • That the appellant had reasonable cause under Section 273B for accepting cash loans, thereby exempting him from penalty. The Commissioner of Income Tax (Appeals) has ignored the proviso to Section

Naseer Ahmath Riswana Fathima, Coimbatore vs. ITO, Non Corp Ward 1(4), Cheenai, Chennai

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

ITA 3415/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Mar 2026AY 2017-18

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3415/Chny/2025 िनधा#रण वष# /Assessment Year: 2017-18

For Appellant: Mr. K.Vishwa padmanabhan, C.A ()For Respondent: Ms. R. Anitha, Addl. CIT
Section 139(1)Section 143(3)Section 250Section 271BSection 44A

Audit, could not be completed on or before 31.10.2015 and said delay was not in the hands of the assessee. Therefore, there is a reasonable cause for not filing the tax audit report within prescribed time limit ad thus, penalty cannot be levied. We find merits in the submission ... case, we are of the considered view that reasons given by the assessee for not filing tax audit report within due date comes under reasonable cause as provided u/s.271B of the Act, and thus, the AO is erred in levying penalty u/s.271B of the Act. Hence, we direct

Kuruzu Russelian, Chennai vs. ITO, Ncc-22(1), Chennai

In the result, the appeal filed by the assessee is allowed and the penalty levied u/s

ITA 2830/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Mar 2026AY 2015-16

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. R. Subramanian, CAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 147Section 148Section 271(1)(c)

Assessing Officer's order is without jurisdiction. 3. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had reasonable cause for the delay in filing the appeal before him. 4. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant could ... Commissioner of Income Tax (Appeals) erred in dismissing the appeal on account of a delay of 241 days without appreciating the genuine and reasonable cause for such delay, which was duly explained in the condonation petition. 8. For that, the Commissioner of Income Tax (Appeals) erred in upholding the penalty

Lakshmanappa Parameshwarappa Prakash, Chikkamagaluru vs. ACIT, Hassan

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

ITA 2271/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Roshan Manssor, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 142(1)Section 250Section 68

appellate authority is otherwise competent to correct the error. Hence, if the application for condonation of delay is rejected despite the existence of reasonable cause, it would amount to allowing an injustice to continue merely on account of technicalities. 8.4 Considering the facts of the present case and the medical ... condition explained by the assessee, we are satisfied that the assessee was prevented by reasonable cause from filing the appeal within the prescribed time. Accordingly, in the interest of justice, the delay of 741 days in filing the present appeal is condoned and the appeal is admitted for adjudication

Rashtra Tej Manch, Mumbai vs. CIT (Exemption), Mumbai

ITA 6957/MUM/2025[2025-26]Status: DisposedITAT Mumbai11 Mar 2026AY 2025-26

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Revenue byFor Respondent: Shri Umashankar Prasad (CIT
Section 12ASection 5Section 80(5)Section 80GSection 80G(5)

filed beyond the time allowed in sub clauses (i) to (vi), the Principle Commissioner or Commissioner may, if he considers that there is a reasonable cause for delay in filing the application, condone such delay and such application shall be deemed to have been filed within the time.” 18. Thus