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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

Kinship Services India Private Limited, Kochi vs. ACIT (TDS), Ernakulam

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

ITA 772/COCH/2025[2007-08]Status: DisposedITAT Cochin07 Nov 2025AY 2007-08

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2007-08 Kinship Services India Pvt. Ltd. .......... Appellant Kinship House, Marar Road, W. Island, Cochi 682003 [Pan: Aabck1973G] Vs. Asst. Commissioner Of Income Tax (Tds), Cochin ...... Respondent Assessee By: Shri Paulson, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 07.11.2025

For Appellant: Shri Paulson, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 201

have heard the rival submissions and perused the record of the appeal files. We are of the considered view that there was reasonable cause for filing the appeal belatedly. Hence, we remand back appeal file to the ld. CIT(A) and direct the ld. CIT(A) to condone the delay

Primary Health Centre Kunnamangalam, Kozhikode vs. ITO, Ward TDS, Kozhikode

In the result, appeals filed by the assessee are dismissed

ITA 764/COCH/2025[2014-15]Status: DisposedITAT Cochin07 Nov 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Richard Mathews, CAFor Respondent: Smt. Leena Lal, Sr. D.R

also, the assessee has not brought on record any sufficient reason for condonation of delay or any evidence to substantiate that there existed a reasonable cause for not filing the appeal within the prescribed time. 6. Recently, the Hon’ble Supreme Court of India in the case

Primary Health Centre Kunnamanagalam Kozhikode, Kozhikode vs. ITO, Ward TDS, Kozhikode

In the result, appeals filed by the assessee are dismissed

ITA 763/COCH/2025[2014-15]Status: DisposedITAT Cochin07 Nov 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Richard Mathews, CAFor Respondent: Smt. Leena Lal, Sr. D.R

also, the assessee has not brought on record any sufficient reason for condonation of delay or any evidence to substantiate that there existed a reasonable cause for not filing the appeal within the prescribed time. 6. Recently, the Hon’ble Supreme Court of India in the case

Primary Health Centre Kunnamangalam Kozhikode, Kozhikode vs. ITO, Ward TDS, Kozhikode

In the result, appeals filed by the assessee are dismissed

ITA 762/COCH/2025[2014-15]Status: DisposedITAT Cochin07 Nov 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Richard Mathews, CAFor Respondent: Smt. Leena Lal, Sr. D.R

also, the assessee has not brought on record any sufficient reason for condonation of delay or any evidence to substantiate that there existed a reasonable cause for not filing the appeal within the prescribed time. 6. Recently, the Hon’ble Supreme Court of India in the case

Primary Health Centre Kunnamangalam, Kozhikode vs. ITO, Ward TDS, Kozhikode

In the result, appeals filed by the assessee are dismissed

ITA 761/COCH/2025[2014-15]Status: DisposedITAT Cochin07 Nov 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Richard Mathews, CAFor Respondent: Smt. Leena Lal, Sr. D.R

also, the assessee has not brought on record any sufficient reason for condonation of delay or any evidence to substantiate that there existed a reasonable cause for not filing the appeal within the prescribed time. 6. Recently, the Hon’ble Supreme Court of India in the case

Vivimed Labs Limited, Hyderabad vs. DCIT., Central Circle 3(4), Hyderabad

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

ITA 601/HYD/2025[2018-19]Status: HeardITAT Hyderabad07 Nov 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144C(13)Section 271BSection 274Section 3Section 44A

grounds, including non- recording of satisfaction by the A.O. in the assessment 4 Vivimed Labs Limited proceedings, and also on the ground of reasonable cause. The Ld. CIT(A), after considering the submissions of the assessee and also taking note of relevant facts, rejected the explanation furnished by the assessee ... case of Chavakkad Service Cooperative Bank Ltd., Vs. ITO [2025] 5 Vivimed Labs Limited 302 taxmann.com 305, submitted that, where there is a reasonable cause for the assessee for not filing the audit report within the prescribed time and further, such audit report was made available to the A.O. before

Alakapuri Sai Mandiram Trust, Hyderabad vs. ITO., Ward-11(1), Hyderabad

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

ITA 1192/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Nov 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1192/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Alakapuri Sai Mandiram Vs. Income Tax Officer Trust, Hyderabad Ward 11(1) Pan:Aadta7032K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri V. Ravish Bhatt, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 30/10/2025 घोषणा की तारीख/Pronouncement: 07/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri V. Ravish Bhatt, Sr.DR
Section 143(1)Section 249(3)

Alkapuri Sai Mandiram Trust Hyderabad before the Ld. First Appellate Authority. Despite such a long delay, the assessee has not explained any reasonable cause for the delay before the Ld. First Appellate Authority. The power to condone delay under section 249(3) of the Act is discretionary on the part ... First Appellate Authority and can be exercised only when the assessee shows sufficient and reasonable cause for not filing the appeal within the prescribed time. In the instant case, as no such reasonable cause has been demonstrated by the assessee before the Ld. First Appellate Authority, the Ld. First Appellate

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT, Central Circle-28, Delhi

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

ITA 6862/DEL/2025[2020-21]Status: DisposedITAT Delhi07 Nov 2025AY 2020-21

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT, Central Circle-28, Delhi

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

ITA 6861/DEL/2025[2019-20]Status: DisposedITAT Delhi07 Nov 2025AY 2019-20

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT, Central Circle-28, Delhi

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

ITA 6860/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Nov 2025AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT, Central Circle-28, Delhi

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

ITA 6859/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT, Central Circle 28, Delhi

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

ITA 6858/DEL/2025[2016-17]Status: DisposedITAT Delhi07 Nov 2025AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT, Central Circle-28, Delhi

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

ITA 6857/DEL/2025[2015-16]Status: DisposedITAT Delhi07 Nov 2025AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Chharia Holding Pvt Ltd, Ghaziabad vs. DCIT Central Circle- 28, Delhi

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

ITA 6856/DEL/2025[2014-15]Status: DisposedITAT Delhi07 Nov 2025AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 153CSection 250

folder, we find that proper opportunity of being heard was not provided to the assessee before disposing of the said appeal though there were reasonable causes for seeking adjournments on the part of the assessee. Keeping in view the power in section

Shanthi Michealanthonyraj Jancy, Palakkad vs. ITO Ward 1 and Tps, Palakkad

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

ITA 701/COCH/2025[2023-24]Status: DisposedITAT Cochin06 Nov 2025AY 2023-24

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2023-24 Shanthi Michealanthonyraj Jancy .......... Appellant Shanthi Nivas, Kozhipathy, Palakkad 678557 [Pan: Cgfpj6644G] Vs. The Income Tax Officer, Ward-1& Tps, Palakkad ....... Respondent Assessee By: Shri Paddmanathan, Advocate Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 03.11.2025 Date Of Pronouncement: 06.11.2025 O R D E R Per Manu Kumar Giri, Jm: The Captioned Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter The “Ld.Cit(A)”]Dated 21.08.2025For The Assessment Year 2023-24 (Hereinafter The "Ay").

For Appellant: Shri Paddmanathan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)

have heard the rival submissions and perused the record of the appeal files. We are of the considered view that there was reasonable cause for filing the appeal belatedly. We find from the explanation given by the assessee as narrated at paras 5 & 6 of argument notes filed

Paravur Government Servants Coop Bank Limited No 123, N Paravur vs. Income Tax Officer, Ward 2, Aluva

In the result, the ITA No

ITA 694/COCH/2025[2019-20]Status: DisposedITAT Cochin06 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Sndeep Gopikrishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 147Section 270ASection 270BSection 271(1)(c)

have heard the rival submissions and perused the record of the appeal files. We are of the considered view that there was reasonable cause for filing the appeal belatedly. Hence, remand back appeal file to the ld.CIT(A) and direct the ld.CIT(A) to condone the delay of 138 days

Paravur Government Servants Coop Bank Limited No 123, N Paravur vs. Income Tax Officer, Ward 2, Aluva

In the result, the ITA No

ITA 693/COCH/2025[2019-20]Status: DisposedITAT Cochin06 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Sndeep Gopikrishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 147Section 270ASection 270BSection 271(1)(c)

have heard the rival submissions and perused the record of the appeal files. We are of the considered view that there was reasonable cause for filing the appeal belatedly. Hence, remand back appeal file to the ld.CIT(A) and direct the ld.CIT(A) to condone the delay of 138 days

Paravur Government Servants Coop Bank Limited No 123, N Paravur vs. ITO Ward 2, Aluva

In the result, the ITA No

ITA 692/COCH/2025[2019-20]Status: DisposedITAT Cochin06 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Shri Sndeep Gopikrishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 147Section 270ASection 270BSection 271(1)(c)

have heard the rival submissions and perused the record of the appeal files. We are of the considered view that there was reasonable cause for filing the appeal belatedly. Hence, remand back appeal file to the ld.CIT(A) and direct the ld.CIT(A) to condone the delay of 138 days

Axiomatic Itech Pvt. Ltd., Ahmedabad vs. The ITO, Ward-1(1)(4), Ahmedabad

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

ITA 191/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri C Dharani Nath, Sr. DR
Section 133(6)Section 143(1)Section 250Section 35(1)Section 35(1)(ii)

above judicial pronouncements, we are satisfied that the delay in filing of the present appeal was due to a bona fide and reasonable cause. The delay cannot be said to be deliberate, negligent, or lacking in good faith. If the delay is not condoned, the assessee will suffer irreparable loss

Yogesh Jashubhai Patel, Ahmedabad vs. The Income Tax Officer, Ward-3(4) Now Ward- 1(2)(1), Ahmedabad

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

ITA 159/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.158/Ahd/2023, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.159/Ahd/2023, Asst.Year 2011-12 Yogesh Jashubhai Patel, The Income Tax Officer Harivallabh Society बनाम/ Ward-3(4) V/S. Naroda Now Ward-1(2)(1) Opp. Devi Cinema Ahmedabad – 380 051 Ahmedabad – 382 345 "थायी लेखा सं./Pan: Audpp 9058 L (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/01/2023 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2011-2012. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.158/Ahd/2023:

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri C. Dharani Nath, Sr.DR
Section 250Section 271(1)(c)

India. Immediately thereafter, he consulted his tax advisor and filed the appeals without any further delay. In our considered view, this explanation constitutes a reasonable cause within the meaning of section 249(3) of the Act. The delay was neither deliberate nor due to negligence but occasioned by genuine circumstances