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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 State Farming Corporation of Kerala Ltd, Kollam vs. ACIT, Kollam Circle, Kollam

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

ITA 819/COCH/2025[2016-17]Status: DisposedITAT Cochin21 Nov 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2016-17 The State Farming Corporation Of Kerala Ltd. .......... Appellant P.B. No. 13, Vettithitta P.O., Punalur 689696 [Pan: Aaact8150F] Vs. Asst. Commissioner Of Income Tax, Kollam ......... Respondent Assessee By: Shri Iype John, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 07.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 03.06.2024 For Assessment Year (Ay) 2016-17. 2. Brief Facts Of The Case Are That The Appellant Is A Government Of Kerala Undertaking Engaged In Production Of Latex & Manufacturing Cenex Out Of It. Apart From Latex Production From Rubber Plantations, The Company Is Engaged In Production Of Cashes, Coconut, Pepper, Plantain, Etc. The Return Of Income For Ay 2015-16 Was Filed On 01.01.2018 Declaring Loss Of Rs. 1,02,61,730/-. Against

For Appellant: Shri Iype John, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 244A

that the appeal had been filed only to take benefit of subsequent decision of the Hon'ble Jurisdictional High Court, which does not constitute reasonable cause for the delay. It only shows that the appellant is not diligent to pursue the appeal. Thus, the appellant had failed to show existence

Sriyans Enterprises Limited, Kolkata vs. I.T.O., Ward - 5(1), Kolkata

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

ITA 1298/KOL/2025[2016-2017]Status: DisposedITAT Kolkata21 Nov 2025AY 2016-2017

Bench: Shri Duvvuru Rl Reddyआयकर अपील सं/Ita No.1298/Kol/2025 ("नधा"रण वष" / Assessment Year : 2016-2017) Sriyans Enterprises Limited, Vs Ito Ward-5(1), Kolkata 22, Brb Basu Road, 1St Floor, Room No.14, Kolkata-700001 Pan No. :Aaics 4667 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Anil Kumar Dugar, Ar राज"व क" ओर से /Revenue By : Shri Sima Das Biswas, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 16/10/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/11/2025 आदेश / O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 13.11.2024 Passed For Assessment Year 2016-2017. 2. The Appeal Of The Assessee Is Filed Belated By 136 Days. In This Regard, The Assessee Has Filed Application For Condonation Of Delay Supported With An Affidavit Stating Sufficient Reasons For Delay. The Contents Of The Application Are As Under :- Before The Hon'Ble Income Tax Appellate Tribunal, Kolkata Bench Ref: Appeal Petition Filed On: In The Matter Of : - An Application For Condonation Of The Delay In Filing The Memorandum Of Appeal Against The Appellate Order Dated 13-11- 2024 Pertaining To Assessment Year 2016-2017; & In The Matter Of The :- A Memorandum Of Appeal Filed Under The Income Tax Act, 1961; & In The Matter Of: -

For Appellant: Shri Anil Kumar Dugar, ARFor Respondent: Shri Sima Das Biswas, Sr. DR

owing to circumstances beyond the control of the appellant and not intentional. 5. The appellant submits and states that: i. There was a reasonable cause for the delay; ii. There was no gross negligence on the part of the petitioner; iii. There was no lack of bona fides

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. Bahwan Cybertek Pvt Ltd, Chennai

ITA 1836/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Nov 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1836/Chny/2024 & C.O.No.62/Chny/2024 (In Ita No.: 1836/Chny/2024) निर्धारण वर्ष / Assessment Year: 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. (अपीलार्थी/Appellant) Bahwan Cybertek Private Limited, Vs. No.148, Bahwan Cybertek It Park, Rajiv Gandhi Salai (Omr), Okkiyam, Thoraipakkam, Chennai - 600 097. [Pan: Aabcb- 2020-P] (प्रत्यर्थी/Respondent/ Cross Objector) It(Tp) A No.: 22/Chny/2024 निर्धारण वर्ष / Assessment Year: 2017-18 Bahwan Cybertek Private Limited, No.148, Bahwan Cybertek It Park, Rajiv Gandhi Salai (Omr), Okkiyam, Thoraipakkam, Chennai - 600 097. [Pan: Aabcb- 2020-P] (अपीलार्थी/Appellant) Vs. Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. N. V. Balaji, Advocate : Shri. Ar. V. Sreenivasan, C.I.T. सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 29.10.2025 : 21.11.2025 आदेश /O R Der Per S. R. Raghunatha, Am : These Appeals Are Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) -16, Chennai [Hereinafter Referred To As The “Ld.Cit(A)”] For The

For Respondent: Shri. N. V. Balaji, Advocate
Section 143(3)Section 250Section 92C

attending those tasks. After considering the affidavit filed by the revenue and also hearing both the parties, we find that there is a reasonable cause for the revenue in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice

Deputy Commissioner of Income Tax, New Delhi vs. Global Agro Corp, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4544/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Dcit Vs Global Agro Corp, Room No.1704, Plot No.07,1St Floor, E-2 Block, Central Market West Civic Centre, Avenue Road, New Delhi-110002. West Punjabi Bagh, New Delhi-110026. Pan-Aakfg2650A Appellant Respondent Revenue By Shri Dheeraj Kumar Jaiswal, Sr.Dr Assessee By Shri Nitin Gulati, Ca Date Of Hearing 17.09.2025 Date Of 21.11.2025 Pronouncement Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 19.07.2024 Passed By Ld. Commissioner Of Income Tax (A), [“Ld.Cit(A)”], National Faceless Appeal Centre (“Nfac”), Delhi In Appeal No. Cit(A), Delhi-15/10990/2019-20 U/S 250 Of The Income Tax Act,1961 [“The Act”] Arising Out Of The Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Partnership Firm, Engaged In Export Of Rice & E-Filed Its Return Of Income On 28.09.2017 Declaring Income At Inr 66,28,650/-. The Case Was Selected Through Cass & After Considering The Submissions Made By The Assessee From Time To Time, Assessment Was Completed U/S 143(3) Vide Assessment Order Dated 31.12.2019 Wherein Following Additions Were Made:

Section 115BSection 143(3)Section 145(3)Section 250Section 40A(2)(b)Section 68

upto 04.11.2016 was neither deposited into the bank accounts nor transferred to head office at Delhi till 04.11.2016.  The assessee failed to furnish any reasonable cause for transfer of such huge cash to such long distance instead of depositing the same at bank account of firm at Gandhi dham. Further

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Ward One Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1742/PUN/2025[2014-15]Status: DisposedITAT Pune20 Nov 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

case. Considering the totality of the facts of the case, we are of the considered opinion that the appellant was prevented by reasonable cause in not filing the appeal within the prescribed time limit & Ld. CIT(A)/NFAC ought to have decided each & every ground raised by the assessee after

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1741/PUN/2025[2015-16]Status: DisposedITAT Pune20 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

case. Considering the totality of the facts of the case, we are of the considered opinion that the appellant was prevented by reasonable cause in not filing the appeal within the prescribed time limit & Ld. CIT(A)/NFAC ought to have decided each & every ground raised by the assessee after

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Ward One Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1740/PUN/2025[2016-17]Status: DisposedITAT Pune20 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

case. Considering the totality of the facts of the case, we are of the considered opinion that the appellant was prevented by reasonable cause in not filing the appeal within the prescribed time limit & Ld. CIT(A)/NFAC ought to have decided each & every ground raised by the assessee after