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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

Sri Ajeya Sankara Trust, Tirupati vs. CIT (Exemption), Hyderabad

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

ITA 1366/HYD/2025[2025-26]Status: DisposedITAT Hyderabad12 Nov 2025AY 2025-26

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1366/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2025-26) Sri Ajeya Sankara Trust Vs. Cit (Exemption) Tirupati Hyderabad Pan:Aaxts2264F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H. Srinivasulu राज" व "ारा/Revenue By:: Dr.Narendra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/10/2025 घोषणा की तारीख/Pronouncement: 12/11/2025 आदेश/Order Per Vijay Pal Rao, Vice-: This Appeal By The Assessee Is Directed Against The Order Dated, 17/05/2025 Of Cit (Exemption) Whereby The Application Of The Assessee In Form 10Ab Seeking Regular Approval U/S 80G Of The Act Was Rejected On The Ground Of Barred By Limitation.

For Appellant: Advocate H. SrinivasuluFor Respondent: : Dr.Narendra Kumar Naik, CIT(DR)
Section 12ASection 2(15)Section 80G

section 80G. 6. Ld CIT(E), Hyd, tailed to appreciate that the delay in filing the application for registration was on account of reasonable cause. 7. Ld. CIT(E), Hyd, failed to consider the Jurisdictional ITAT Hyderabad decision in KMV Foundation (176 Taxmann.com ... amendment is brought to the Act whereby the powers are vested with the Pr. CIT/CIT for condonation of the delay, if there is a reasonable cause for filing the application. Thus, the learned Counsel for the assessee has submitted that in view of the amendment of inserting the proviso

Thiruvarur Lions Eye Hospital Trust, Thiruvarur vs. Income Tax Officer, Thiruvarur

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

ITA 2535/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Nov 2025AY 2018-19

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

For Appellant: Shri D. Ambarish, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 10Section 139Section 143(3)Section 147Section 148Section 250Section 272A(2)(e)

Loss is also more than the maximum amount which is not chargeable to tax. 6. The Learned CIT(A) failed to appreciate the reasonable cause that the founder trustee who looked after the accounts was a very senior citizen aged more than 80 years and fell ill health shall also ... appreciate the fact that the delay in filing return of income was neither intentional nor to derive undue benefit but due to genuine and reasonable cause. 11. The appellant craves leave to add, alter, amend or withdraw any of the above grounds appeal at the time of hearing. 3. Brief

Thiruvarur Lions Eye Hospital Trust, Thiruvarur vs. Income Tax Officer, Thiruvarur

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

ITA 2531/CHNY/2025[2016-17]Status: DisposedITAT Chennai11 Nov 2025AY 2016-17

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

For Appellant: Shri D. Ambarish, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 10Section 139Section 143(3)Section 147Section 148Section 250Section 272A(2)(e)

Loss is also more than the maximum amount which is not chargeable to tax. 6. The Learned CIT(A) failed to appreciate the reasonable cause that the founder trustee who looked after the accounts was a very senior citizen aged more than 80 years and fell ill health shall also ... appreciate the fact that the delay in filing return of income was neither intentional nor to derive undue benefit but due to genuine and reasonable cause. 11. The appellant craves leave to add, alter, amend or withdraw any of the above grounds appeal at the time of hearing. 3. Brief

D Ajeethraj Chordia & Sons, Chennai vs. ITO, Non Corporate Ward -4(5), Chennai

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

ITA 2143/CHNY/2025[2012-13]Status: DisposedITAT Chennai11 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.: 2143/Chny/2025 िनधा"रण वष"/Assessment Year:2012-13 M/S. D Ajeethraj Chordia & The Income Tax Officer, Sons, Non Corporate Ward – 4(5), 23, General Muthia Mudali Vs. Chennai Street, Sowcarpet, Chennai – 600 079. Pan: Aaahd 2647C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri S. Girish Kumar, Advocate ""यथ" क" ओर से/Respondent By : Ms. Pryati Sharma, Jcit सुनवाई क" तारीख/Date Of Hearing : 30.10.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

For Appellant: Shri S. Girish Kumar, AdvocateFor Respondent: Ms. Pryati Sharma, JCIT
Section 154Section 226Section 234BSection 246A

submitted that pursuing the alternate remedy available under the Act in the form of rectification proceeding under section 154 of the Act would constitute reasonable cause for the belated filing of the appeal under consideration. He relied upon the judgment of the Jurisdictional High Court in the case reported ... approved the belated filing of appeal in pursuance to the alternate remedy pursued by the assessee which according to the court would constitute reasonable cause for permitting the Assessee in pursuing the belated appeal on merits. 4. The Ld. DR Ms. Pryati Sharma, JCIT pleaded for dismissal of the appeal

Aa 293 Panahalli Primary Agricultural Cooperative Credit Society Limited, Erode vs. The Income Tax Officer, Ward 2(1), Erode

In the result, the appeals filed in ITA Nos

ITA 2022/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Nov 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2020, 2021 & 2022/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Aa 293 Panahalli Primary Agricultural Vs. The Income Tax Officer, Cooperative Credit Society Limited, Ward 2(1), 1, Panakkahally, Thalavady Post, Erode. Erode 638 461. [Pan: Aacaa1566A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per Bench: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders All Dated 27.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21 Towards Disallowance Of Deduction Claimed Under Section 80P Of The Income Tax Act, 1961 [“Act” In Short], Levy Of Penalty Under Section 270A Of The Act & Levy Of Penalty Under Section 272(1)(D) Of The Act By Rejecting The Prayer Of Condonation Of Delay In Filing The Appeals Before The Ld. Cit(A).

For Appellant: Ms. A. Vijayalakshmi, C.A. (Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144Section 270ASection 272(1)(d)Section 80P

days. 5. The ld. AR Ms. A. Vijayalakshmi, C.A., referring to Col. 15 of Form 35 and submits that the assessee has furnished the reasonable cause for the delay in filing the appeal. She further drew our attention para 5.2.2 page 5 of the impugned order, wherein, hearing notices were ... Considering the submissions of the ld. AR, the reasons stated by the assessee for the delay in filing the appeal, are found to be reasonable cause. Accordingly, we direct the ld. CIT(A) to condone the delay and adjudicate the issues on merits after considering the submissions/ evidences

Aa 293 Panahalli Primary Agricultural Cooperative Credit Society Limited, Erode vs. The Income Tax Officer Ward 2(1), Erode

In the result, the appeals filed in ITA Nos

ITA 2021/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Nov 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2020, 2021 & 2022/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Aa 293 Panahalli Primary Agricultural Vs. The Income Tax Officer, Cooperative Credit Society Limited, Ward 2(1), 1, Panakkahally, Thalavady Post, Erode. Erode 638 461. [Pan: Aacaa1566A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per Bench: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders All Dated 27.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21 Towards Disallowance Of Deduction Claimed Under Section 80P Of The Income Tax Act, 1961 [“Act” In Short], Levy Of Penalty Under Section 270A Of The Act & Levy Of Penalty Under Section 272(1)(D) Of The Act By Rejecting The Prayer Of Condonation Of Delay In Filing The Appeals Before The Ld. Cit(A).

For Appellant: Ms. A. Vijayalakshmi, C.A. (Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144Section 270ASection 272(1)(d)Section 80P

days. 5. The ld. AR Ms. A. Vijayalakshmi, C.A., referring to Col. 15 of Form 35 and submits that the assessee has furnished the reasonable cause for the delay in filing the appeal. She further drew our attention para 5.2.2 page 5 of the impugned order, wherein, hearing notices were ... Considering the submissions of the ld. AR, the reasons stated by the assessee for the delay in filing the appeal, are found to be reasonable cause. Accordingly, we direct the ld. CIT(A) to condone the delay and adjudicate the issues on merits after considering the submissions/ evidences

Aa 293 Panahalli Primary Agricultural Cooperative Credit Society Limited, Erode vs. The Income Tax Officer, Ward 2(1), Erode

In the result, the appeals filed in ITA Nos

ITA 2020/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Nov 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2020, 2021 & 2022/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Aa 293 Panahalli Primary Agricultural Vs. The Income Tax Officer, Cooperative Credit Society Limited, Ward 2(1), 1, Panakkahally, Thalavady Post, Erode. Erode 638 461. [Pan: Aacaa1566A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per Bench: These Three Appeals Filed By The Assessee Are Directed Against Separate Orders All Dated 27.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21 Towards Disallowance Of Deduction Claimed Under Section 80P Of The Income Tax Act, 1961 [“Act” In Short], Levy Of Penalty Under Section 270A Of The Act & Levy Of Penalty Under Section 272(1)(D) Of The Act By Rejecting The Prayer Of Condonation Of Delay In Filing The Appeals Before The Ld. Cit(A).

For Appellant: Ms. A. Vijayalakshmi, C.A. (Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144Section 270ASection 272(1)(d)Section 80P

days. 5. The ld. AR Ms. A. Vijayalakshmi, C.A., referring to Col. 15 of Form 35 and submits that the assessee has furnished the reasonable cause for the delay in filing the appeal. She further drew our attention para 5.2.2 page 5 of the impugned order, wherein, hearing notices were ... Considering the submissions of the ld. AR, the reasons stated by the assessee for the delay in filing the appeal, are found to be reasonable cause. Accordingly, we direct the ld. CIT(A) to condone the delay and adjudicate the issues on merits after considering the submissions/ evidences

Tarun Jain, Faridabad vs. ITO Ward 2(4) Fbd, Faridabad

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

ITA 4193/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmantarun Jain, Vs. Ito, Ward 2 (4), House No.641, Sector 7B, Faridabad. Faridabad – 121 006 (Haryana). (Pan : Agepj5824D) (Appellant) (Respondent) Assessee By : Shri Neeraj Goyal, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 11.11.2025 Date Of Order : 11.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 28.02.2025 For The Assessment Year 2017-18. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Submitted That The Assessee Has Filed The Appeal With A Delay Of 62 Days From The Date Of Appellate Order. He Submitted That On January 7, 2025, A Robbery Took Place At The Assessee’S Shop For Which An Fir Was Registered In Sector 8, Faridabad, A Copy Of The Same Is Placed On Record & This Unfortunate Incident Caused

For Appellant: Shri Neeraj Goyal, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(1)(a)Section 143(3)Section 270ASection 274

delay. We have heard both the counsels on the issue of condonation of delay. In 4. our considered opinion, there was a reasonable cause for the delay in filing the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal. Brief facts of the case are, assessment