“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

Dipakraj Krishnamuni Marathe, Jalgaon vs. ITO Ward 1(4), Jalgaon

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

ITA 708/PUN/2025[2017-18]Status: DisposedITAT Pune31 Oct 2025AY 2017-18

Bench: Dr.Manish Borad

For Appellant: Shri Sarang GudhateFor Respondent: Shri R.Y. Balawade

Section 139Section 142(1)Section 144Section 250Section 270ASection 69A

said period. On going through the averments made in the affidavit along with the death certificate placed of record, I am satisfied that ‘reasonable cause’ 2 Dipakraj Krishnamuni Marathe prevented the assessee to file the appeal within the stipulated time. I note that the delay is not intentional and assessee

Rama Damu Bhagat, Panvel vs. ITO Ward-1, Panvel

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

ITA 2109/PUN/2025[2013-14]Status: DisposedITAT Pune31 Oct 2025AY 2013-14

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2109/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Rama Damu Bhagat, V The Income Tax Officer, Room No.4, Yashoganga S Ward-1, Panvel. Chg, Tilak Road, Panvel – 410206. Maharashtra. Pan: Bicpb8875P Appellant/ Assessee Respondent / Revenue Assessee By Ca Ajinkya Vaishampayan(Virtual Hearing) Revenue By Shri Sandeep Sathe – Jcit(Dr) Date Of Hearing 08/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2013-14 Dated 25.09.2023 Emanating From The Assessment Order Under Section 144 R.W.S 147 Of The Income Tax Act, 1961 Dated 14.11.2019. The Grounds Of Appeal Raised By The Assessee Are As Under :

Section 144Section 148Section 207(2)Section 207(2)(b)Section 249(4)(b)Section 250Section 48

Citizen 85 years old and suffering from physical disability as mentioned in the Medical Certificate. Therefore, we are convinced that there was sufficient and reasonable cause for delay. Hence, the Delay is condoned. 11. In the result, appeal of the Assessee is allowed for statistical purpose. Order pronounced

Om J J Swa Vishwashanti Dham Nirman Sanstha, Verul vs. ITO Exemption Ward, Aurangabad

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

ITA 2090/PUN/2025[2015-16]Status: DisposedITAT Pune31 Oct 2025AY 2015-16

Section 11Section 12ASection 143(1)Section 250

days in filing appeal before this Tribunal. We have perused the request of the Assessee and are convinced that there is sufficient and reasonable cause for delay, accordingly, the Delay in condoned. Submission of ld.AR : 3. Ld.AR for the Assessee submitted that Assessee Trust had filed Return of Income

Bible Fellowship Centre Wagholi, Pune vs. ITO, Exemption, Ward-1(2), Pune

In the result, appeal filed by the assessee is allowed as per the terms indicated above

ITA 1887/PUN/2025[2016-17]Status: DisposedITAT Pune31 Oct 2025AY 2016-17

Bench: Dr.Manish Borad

For Appellant: Shri B.C. MalakarFor Respondent: Shri Manoj Tripathi

Section 11Section 11(1)(a)Section 139(1)Section 143(2)Section 143(3)Section 80G

Commissioners will, while entertaining such belated applications in Form No. 9A and Form No.10, satisfy themselves that the assessee was prevented by reasonable cause from filing of applications in Form No. 9A and Form No.10 within the stipulated time. Further, in respect of Form No. 10 the Commissioners shall also

Shree Sant Savta Gramin Bigar Seti Sahakari Pathsansta Marayadit, Nashik vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal of the Assessee is partly allowed

ITA 1625/PUN/2025[2017-18]Status: DisposedITAT Pune31 Oct 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1625/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Shree Sant Savta Gramin Bigar V Assessment Unit, Seti Sahakari Pathsanstha S. Income Tax Department, Maryadit, Delhi. Pimpalgaon, Niphad, Nashik – 422209. Pan: Aacas4098M Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Dayanand Jawalikar – Addl.Cit Date Of Hearing 14/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18, Dated 27.11.2024 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 15.12.2019. The Assessee Has Raised Following Grounds Of Appeal :

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68Section 80PSection 80P(2)(a)Section 80P(2)(d)

days in filing appeal before this Tribunal. We have perused the Affidavit submitted by the Assessee and are convinced that there is sufficient and reasonable cause for the delay. Therefore, the Delay is condoned. 2. At the outset of hearing, no one appeared on behalf of the assessee. No adjournment

Harmony Educational Foundation, Pune vs. CIT(E), Pune

In the result, appeal of the Assessee is dismissed

ITA 1993/PUN/2024[2025-26]Status: DisposedITAT Pune31 Oct 2025AY 2025-26

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1993/Pun/2024 निर्धारण वषा / Assessment Year: 2025-26 Harmony Educational V The Commissioner Of Foundation, S Income Tax(Exemption), 1430, Satav Vasti, Wagholi Pune. Lohegaon Road, Wagholi, Pune – 411047. Maharashtra. Pan: Aafch1576E Appellant/ Assessee Respondent / Revenue Assessee By Ca Abhay A Avchat & Mrs.Ruchi Agarwal(Director) – Ar Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 28/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption) Dated 24.07.2024 Rejecting Registration Under Section 12A(1)(Ac) Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal:

Section 12ASection 12A(1)(ac)

filing appeal before this Tribunal. We have perused the request of the Assessee and are convinced that there is sufficient and reasonable cause for delay, accordingly, the Delay in condoned. 2 ITA No.1993/PUN/2024 [A] Brief facts of the case : 3. In this case, Assessee i.e. Harmony Educational Foundation filed

Ekashila Reddy Sankshema Sangam, Warangal vs. Income Tax Officer, Ward-1, Warangal

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

ITA 911/HYD/2025[2018-19]Status: DisposedITAT Hyderabad31 Oct 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.911/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Ekashila Reddy Vs. Income Tax Officer Sankshema Sangam, Ward 1 Warangal Warangal Pan:Aaaae8858K (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Gurpreet Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 31/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Gurpreet Singh, Sr.DR

Section 147

opposed the condonation of delay and supported the order of the Ld. CIT(A). It was contended that the assessee had failed to show reasonable cause before the Ld. CIT(A) for condonation, and hence, there was no infirmity in the action of the Ld. CIT(A) in dismissing ... President of the society during the relevant period. In our considered view, the delay is minor and unintentional, and the explanation offered constitutes a reasonable cause. It is a settled principle that technicalities should not defeat substantial justice. Accordingly, Page 4 of 6 ITA No 911 of 2025 Ekashila Reddy

Mohd Noorul Huda, Hyderabad vs. ITO., Ward-9(1), Hyderabad

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

ITA 843/HYD/2025[2017-18]Status: DisposedITAT Hyderabad31 Oct 2025AY 2017-18

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons in both the appeals that, against the order passed under Section 147 r.w. Section 144 dated 17.03.2022, an appeal was filed before the CIT(A) on 10.10.2023. In Form No.35, the assessee had provided the email ID mohdnoorulhuda513@gmail.com and opted not to receive communication by email. However, the CIT(A) sent the notices and the order under Section 250 to the old email ID noorulhuda80085@gmail.com, to which the asses

Section 142(1)Section 147Section 148Section 250Section 69A

Gurpreet Singh, learned Senior A.R., for the Revenue, on the other hand, did not strongly oppose the condonation of delay, in view of the reasonable cause explained by the assessee. 4. We have heard both the parties and perused the petition and affidavit filed by the assessee seeking condonation ... filing the appeals before the Tribunal. We find that, the reasons explained by the assessee appear to be genuine and bonafide and come under reasonable cause. We further find that, the Hon’ble Supreme Court in the case of Collector, Land Acquisition vs. MST Katiji

Mohd Noorul Huda, Hyderabad vs. ITO., Ward-9(1), Hyderabad

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

ITA 842/HYD/2025[2016-17]Status: DisposedITAT Hyderabad31 Oct 2025AY 2016-17

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons in both the appeals that, against the order passed under Section 147 read with Section 144 dated 17.03.2022, an appeal was filed before the CIT(A) on 10.10.2023. In Form No.35, the assessee had provided the email ID mohdnoorulhuda513@gmail.com and opted not to receive communication by email. However, the CIT(A) sent the notices and the order under Section 250 to the old email ID noorulhuda80085@gmail.com, to which the

Section 142(1)Section 147Section 148Section 250Section 69A

Neo Seeds India Private Limited, Hyderabad vs. ITO., Ward-16(1), Hyderabad

ITA 1426/HYD/2025[2018-19]Status: DisposedITAT Hyderabad31 Oct 2025AY 2018-19

Bench: Us:

Section 115JSection 143(3)Section 282Section 35Section 37(1)

reason to differ with the findings of the AO since no attempt has been made by the appellant to discharge its onus of furnishing reasonable cause /explanation/ documents in support of his claim made in the ground of appeal as to why penalty is not attracted in this case. Hence

Kapa Sindhu Mitra, Usa vs. Income Tax Officer (Int Taxn)-1, Hyderabad

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

ITA 513/HYD/2024[2016-17]Status: DisposedITAT Hyderabad31 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.513/Hyd./2024 िनधा"रण वष"/Assessment Years 2016-2017 Kapa Sindhu Mitra, 20148, Holly Hock Terrace, The Income Tax Officer – Ash Burn, V A, Vs. [Int. Taxn)-1, Hyderabad – 500 004. United States Of America. Pan Azcpk8030D (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri Sashank Dundu, Advocate राज" व "ारा/Revenue By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 29.10.2025 घोषणा की तारीख/Pronouncement: 31.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri Sashank Dundu, AdvocateFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 144C(5)Section 147Section 148Section 148ASection 149Section 151A

delay due to an inadvertent mistake on the part of the learned Authorised Representative of the Assessee. Therefore, the assessee has explained a reasonable cause for delay of 01 day. Accordingly, in the facts and circumstances of the case and in the interest of justice, we condone the delay

ACIT, Central Circle-2(2), Hyderabad vs. Rithwik Projects Private Limited, Hyderabad

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

ITA 518/HYD/2022[2019-20]Status: DisposedITAT Hyderabad31 Oct 2025AY 2019-20

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, P Murali Mohan RaoFor Respondent: Shri Madan Mohan Meena (in

Section 132Section 142(1)Section 143(2)Section 35DSection 37(1)

furnishing relevant evidence. Since there is a delay of 871 days in the cross-objection filed by the assessee, which was not explained with reasonable cause, and further, the cross- objection filed by the assessee only supports the order of the Ld. CIT(A) without any grounds which ... furnishing relevant evidence. Since there is a delay of 871 days in the cross-objection filed by the assessee, which was not explained with reasonable cause, and further, the cross- objection filed by the assessee only supports the order of the Ld. CIT(A) without any grounds which

Abhishek Mehta, Chennai vs. ITO, Corporate Circle-2(1), Chennai

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

ITA 1509/CHNY/2025[2018-19]Status: DisposedITAT Chennai31 Oct 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1509/Chny/2025 िनधा9रण वष9 /Assessment Year: 2018-19 Abhishek Mehta, The Income Tax Officer, No.8, Suraj Kunj, Rutland Gate, Vs. Corporate Circle-3(1), 5Th Street, Nungambakkam, Chennai. Chennai – 600 006. [Pan: Adxpa 8566D]

For Appellant: Shri Hitesh, AdvocateFor Respondent: Shri Nishanth Rao, JCIT

Section 271BSection 44ASection 57

director. Considering these facts, we are of the view that assessee was not required to get books audited u/s 44AB . Further, there was a reasonable cause for the assessee’s failure to get his accounts audited under section 44AB of the Act, as assessee has been showing interest income under

Attivo Protezione Private Limited, Mumbai vs. Income Tax Officer Ward-22(1)(1), Lalbaug

ITA 5380/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosainattivo Protezione Pvt Ltd Vs. Ito, Ward – 22(1)(1) 108, 1St Floor Ashar Enclave Room No. 319, Piramal Kolshet Road, Thane – 400 Chambers, Mumbai 607. Pan/Gir No. Aalca4330M (Applicant) (Respondent)

Section 250Section 5

automatic right but requires the person requesting it to provide a valid explanation for each day of delay and demonstrate a reasonable cause. “Sufficient Cause” cannot be liberally interpreted, if negligence, inaction or lack of bona fides is attributed to the party. In the case of Anshul Agarwal

Nashabandi Mandal Maharashtra State, Mumbai vs. CIT(Exemption), Mumbai

In the result, both the appeals filed by the assessee stands allowed for statistical purposes

ITA 5099/MUM/2025[N.A]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar

For Appellant: Shri Mohammed ImtiyazFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. Sr.A.R

Section 12Section 12A

holding as under: “That the reasons for delay are neither satisfactory nor conclusive. Further the Assessee has not been able to show any reasonable cause for delay or to establish that the assessee trust had genuine hardship in filing of the application date. Therefore, the application for condonation of delay

Nashabandi Mandal Maharashtra State Charitable Institution, Mumbai vs. CIT(Exemption), Mumbai

In the result, both the appeals filed by the assessee stands allowed for statistical purposes

ITA 5098/MUM/2025[N.A]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar

For Appellant: Shri Mohammed ImtiyazFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. Sr.A.R

Section 12Section 12A

Rajan Pradeepkumar Dubey, Dombivli (E) vs. Income Tax Officer - 3(2), Kalyan

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

ITA 4296/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankarrajan Pradeepkumar Debey Vs. Ito – 3(2) E/11, Flat No. 002, Rani Mansion, Murbad Deshmukh Home Bldg, Tata Road, Kalyan – 421301 Power House, Tata Power Lane, Dombivli (E), 421201 Pan/Gir No. Bbzpd9784K (Applicant) (Respondent)

Section 250

assessee and considering the fact that there was misunderstanding and communication gap between the assessee and his tax consultant which amounts to a reasonable cause, because of which assessee could not put effective representation before Ld. CIT(A). Hence the Bench is of the view that one more opportunity

Chandarkishor Nandkishor Seksaria, Mumbai vs. Income Tax Officer Ward 42(2)(1), Mumbai

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

ITA 4203/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawalchandarkishore Vs. Ito, Ward 42(2)(1) Nandkishore Seksaria Kautilya Bhawan, Bkc 70, Seksaria House, Jb Bandra (E) – 400 051. Nagar, Andheri (E), Mumbai – 400 059. Pan/Gir No. Amxps4815N (Applicant) (Respondent)

Section 142(1)Section 144Section 148Section 250Section 270A

that as it may, without going into the merits of the issues raised by the assessee and considering the fact that there was reasonable cause, because of which assessee could not put effective representation before Ld. CIT(A). Hence the Bench is of the view that one more opportunity

Rakesh Ramadhar Singh, Mumbai vs. Income Tax Officer Ward 2(3)(2), Mumbai

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

ITA 4027/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Shri Beena Pillai & Smt.Renu Jauhrirakesh Ramadhar Singh Vs. Income Tax Officer, 304, B-Wing Dolphin Ward 2(3)(2), Heritage, Nehru Road, Opp. Room No. 581A, Military Camp, Santacruz 5Th Floor, Aayakar Bhavan, East, Maharishi Karve Road, Mumbai-400029. Mumbai-400020. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Altps1647P Appellant .. Respondent

For Appellant: Shri Ramesh JainFor Respondent: Shri Annavaran Kosuri- Sr. AR

Section 144Section 147Section 250

which occurred due to genuine and bonafide reasons. After considering the submissions of the assessee, we hereby condone the delay being on account of reasonable cause. 4. Brief facts of the case are that the assessee was engaged in the business of clearing and forwarding services. Due to reduced turnover

Rahi Motor Transport Co, Mumbai vs. Asst. Commissioner of Income Tax Circle 23(3), Mumbai

ITA 1845/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER