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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

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

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

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

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

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

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

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

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

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

ITA 1844/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

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

Rajkumar Dube, Mumbai vs. ITO -21(3)(1), Mumbai

In the result, Assessee’s appeal is allowed for statistical purposes

ITA 1125/MUM/2025[2013-14]Status: DisposedITAT Mumbai31 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Choudhryrajkumar Dube, Ito, Ward-21(3)(1), Prakash Building 3/6, Mumbai. Senapati Bapat Marg, Room No 207, 2Nd Floor, Next To Indian Bank, Vs. Piramal Chambers, Lalbaug, Dadar West, Mumbai. Mumbai- 400012 Pan : Aehpd 1582 K (Appellant) (Respondent)

For Appellant: Shri Hari S. Rahej, Ld. AdvocateFor Respondent: Shri Pushkaraj Bhangepatil, Ld. Sr.DR

invitation cards qua marriage of his niece and nephew at his native place i.e. Gonda District Uttar Pradesh, has also tried to establish the reasonable cause. The Ld. counsel for the Assessee has also submitted that since 2019 onwards, the Assessee is suffering a lot, as not only medical exigencies ... delay period, medical documents and events and demonstrated the gap in between. Further the Ld. DR has submitted that there is no reasonable cause, shown by the Assessee and as such the sequence of delay is not sync with documents submitted by the Assessee and therefore in any case

Garrison Engineer (E/M), Maharajpur vs. ITO., (TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 135/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Garrison Engineer(E/M), Maharajpur vs. ITO., (TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 134/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Garrison Engineer (E/M), Gwalior vs. ITO, (TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 133/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Garrison Engineer (E/M), Gwalior vs. ITO.(TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 132/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Garrison Engineer (E/M), Maharajpur vs. JCIT., (TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 131/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Garrison Engineer (E/M) Air Force Station, Maharjpur vs. JCIT(TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 130/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and deposited in time. The appellant assessee, being a Central Govt. entity, the decisions relied

Garrison Emgomeer (E/M), Air Firce Station, Maharajpur vs. JCIT.(TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 129/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Garrison Emgomeer (E/M) Air Force Station, Maharajpur vs. Joint Commissioner of Income Tax, (TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 128/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

penalty provision under Section 272A(2) is subject to the saving clause under Section 273B. Section 273B, which provides immunity from penalty if reasonable cause is established for such failure. In the instant case, the appellant assessee has contended that he was not afforded proper opportunity to make his submissions ... before the authorities below so as to demonstrate the reasonable cause for not filing the requisite statements in Form 24Q and the absence of mala fide intention when the tax has been deducted and 6 | P a g e ITA No. deposited in time. The appellant assessee, being a Central

Mahendra Singh Rathore, Bilara vs. Ld. AO Ward 3(5), Jodhpur

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

ITA 515/JODH/2024[2017-18]Status: DisposedITAT Jodhpur30 Oct 2025AY 2017-18

Bench: The Ld. Cit(A). The Ld. Cit(A) Confirmed Major Additions Except Partly Allowing Deduction U/S 80C.

For Appellant: Ms. Divya Phophalia, C.AFor Respondent: Shri Arvind Kumar Gehlot, Addl. CIT-DR

Section 143(2)Section 144Section 44ASection 69ASection 80C

health and prolonged illness, the assessee could neither attend assessment proceedings nor effectively file submissions before the Ld. CIT(A). The illness, being a reasonable cause, was pleaded to be taken into consideration while condoning non-compliance. 5.2 It was further argued that the assessee is in a position ... claims. 7.1 At the same time, we find merit in the submission of the Ld. AR that the assessee was prevented by reasonable cause, namely illness, from effectively pursuing the proceedings. The principles of natural justice require that an assessee be afforded adequate opportunity to present his case. 7.2 Considering

Sukhad Jeevan Sansthan, Chittorgarh vs. CIT (Exemption) Jaipur, Jaipur

In the result, the appeal of the assessee is dismissed

ITA 447/JODH/2024[2023-24]Status: DisposedITAT Jodhpur30 Oct 2025AY 2023-24

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 10Section 11Section 12Section 80GSection 80G(5)

provided in the Act. There is no such provision nor there is any power to condone the delay after Considering the reasonable reasons. A reasonable cause can be taken into cognizance for condoning the delay, if such provision is provided in the Act while considering any issue for adjudication. Therefore

Tirupati Shyam Enterprise, Surat vs. DCIT, Circle 1(1)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 318/SRT/2025[2015-16]Status: DisposedITAT Surat30 Oct 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-2016 Tirupati Shyam Enterprise Nfac, Delhi Current F.P. No. 139 Orleaans, Near Jurisdiction: Dy. Cit Circle- Sosyo Circle Udhna Magadalla Vs. 1(1)(1), Road, Surat-395007. Aayakar Bhavan, Near Majura Gate, Opp. New Civil Hospital, Surat-395001. Pan No. Aagft 3570 Q Appellant Respondent

For Appellant: Mr. J.K. Chandnani, Sr. DRFor Respondent: Mr. Rasesh Shah, CA

Section 147Section 148Section 5Section 68

prevented by sufficient was not intentional and I was prevented by sufficient was not intentional and I was prevented by sufficient and reasonable cause for not filing the appeal in time. and reasonable cause for not filing the appeal in time. 5) That therefore, in the facts and circumstances

Kollam District Police Department Employees Co-Operative Society, Kollam vs. ITO, Ward-2, Kollam

In the result, the appeal filed by the assessee bearing ITA No

ITA 639/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Kollam District Police Department .......... Appellant Employees Co-Operative Society Lt No Q 1179, Near S P Office, Kollam-691001 [Pan: Aacak5573H] Vs. Assessment Unit, Income Tax Department ......... Respondent Assessee By: Shri Surendranath Rao, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Assessment Year: 2013-14 Porkulam Service Co-Op. Bank Ltd. .......... Appellant (Via) Pazhanji, Thalappilly, Thrissur- 680542 [Pan: Aaaap4486A] Vs. The Income Tax Officer, W-1& Tps ......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 30.10.2025 Kollam District Police Deptt. Employees Co.Op. Society & Porkulam Scb O R D E R Per: Anikesh Banerjee, Jm The Instant Appeal Of Both The Assessee Was Filed Against The Order Of The Learned National Faceless Appeal Centre, Delhi [For Brevity, ‘Ld. Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, The Act’) For Assessment Year 2017-18, Date Of Order 10/07/2025 For Petitioner-1 & For Assessment Year 2013-14, Date Of Order 25/06/2025 For Petitioner-2.The Impugned Orders Were Emanated From The Order Of The Assessment Unit, Income Tax Department (In Short, ‘Ld. Ao’) Order Passed Under Section 271B Of The Act, Date Of Order 12/07/2023 For Ay Petritioner-1 &19/09/2022 For Petitioner-2. 2. Both The Appeals Have Common Issue & Common Fact. So, We Proceed To Dispose Off By Common Order. Ita No. 639/Coch/2025 Is Taken As Lead Case.

For Appellant: Shri Surendranath Rao, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 139(1)Section 143(3)Section 250Section 271BSection 44ASection 80P(2)(a)

assessments, since delay in obtaining audit reports from statutory auditors under Kerala Co-operative Societies Act and Rules could be seen as a reasonable cause for delayed submission of audit reports, no penalty under section 271B was to be imposed on assessee 6. The Ld. DR argued and stood

Amphenol Fci India Private Limited, Kochi vs. DCIT Corporate Circle 1(1), Kochi

In the result, appeal of the assessee bearing ITA

ITA 619/COCH/2025[2016-17]Status: DisposedITAT Cochin30 Oct 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Amphenol Fci India Pvt. Ltd. .......... Appellant Xxix/2089 Tripunithura Road, Thykoodam Vyttila S.O., Kochi 682019 [Pan: Aaaco2006R] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Govind Shekhar, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 30.10.2025

For Appellant: Shri Govind Shekhar, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(2)Section 143(3)Section 250

appeal due absence of vouchers & evidence. Having considered the totality of facts and circumstances, we are of the view that the assessee has demonstrated reasonable cause for the non-submission of documents before the Ld. CIT(A) & Ld. AO. It is also evident that during the assessment & appellate proceedings

Porkulam Service Co-Op.Bank Ltd, Thalappilly vs. Incometax Officer, Guruvayoor

In the result, the appeal filed by the assessee bearing ITA No

ITA 605/COCH/2025[2013-14]Status: DisposedITAT Cochin30 Oct 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Kollam District Police Department .......... Appellant Employees Co-Operative Society Lt No Q 1179, Near S P Office, Kollam-691001 [Pan: Aacak5573H] Vs. Assessment Unit, Income Tax Department ......... Respondent Assessee By: Shri Surendranath Rao, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Assessment Year: 2013-14 Porkulam Service Co-Op. Bank Ltd. .......... Appellant (Via) Pazhanji, Thalappilly, Thrissur- 680542 [Pan: Aaaap4486A] Vs. The Income Tax Officer, W-1& Tps ......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 30.10.2025 Kollam District Police Deptt. Employees Co.Op. Society & Porkulam Scb O R D E R Per: Anikesh Banerjee, Jm The Instant Appeal Of Both The Assessee Was Filed Against The Order Of The Learned National Faceless Appeal Centre, Delhi [For Brevity, ‘Ld. Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, The Act’) For Assessment Year 2017-18, Date Of Order 10/07/2025 For Petitioner-1 & For Assessment Year 2013-14, Date Of Order 25/06/2025 For Petitioner-2.The Impugned Orders Were Emanated From The Order Of The Assessment Unit, Income Tax Department (In Short, ‘Ld. Ao’) Order Passed Under Section 271B Of The Act, Date Of Order 12/07/2023 For Ay Petritioner-1 &19/09/2022 For Petitioner-2. 2. Both The Appeals Have Common Issue & Common Fact. So, We Proceed To Dispose Off By Common Order. Ita No. 639/Coch/2025 Is Taken As Lead Case.

For Appellant: Shri Surendranath Rao, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 139(1)Section 143(3)Section 250Section 271BSection 44ASection 80P(2)(a)

assessments, since delay in obtaining audit reports from statutory auditors under Kerala Co-operative Societies Act and Rules could be seen as a reasonable cause for delayed submission of audit reports, no penalty under section 271B was to be imposed on assessee 6. The Ld. DR argued and stood

Dy.Commissioner of Income Tax, Thrissur vs. The Csb Bank Ltd, Thrissur

In the result, the appeal of revenue is dismissed

ITA 542/COCH/2025[2014-15]Status: DisposedITAT Cochin30 Oct 2025AY 2014-15

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Satish Modi, CAFor Respondent: Shri. Sanjit Kumar Das, CIT DR

Section 115Section 115JSection 144BSection 147Section 250

load being handled by the assessing officer concerned at the relevant time. Therefore, we are of the view that the Revenue was prevented by reasonable cause from filing appeal within the prescribed time and that no benefit would have accrued to the Revenue by delaying filing of the present appeal

Sayegh Paint Factories India Private Limited, Ernakulam vs. Corporate Cir 2(1), Kochi

In the result, the appeal filed by the assessee is allowed and the stay petition is dismissed as infructuous

ITA 451/COCH/2025[2019-20]Status: DisposedITAT Cochin30 Oct 2025AY 2019-20

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr.AR

Section 144B(6)(vii)Section 148Section 271BSection 273BSection 44A

person OR the assessee, as the case may be, for any failure referred to in the said provisions if he proves that there was reasonable cause for the said failure. 10- The learned commissioner (appeals) failed to consider the genuine and documented reason for delay in filing the audit report ... penalty imposed under Section 271B of the Act. - Hold that the 6 delay in filing the audit report was due to a Rs.0 reasonable cause and therefore protected under Section 273B; and - Pass any other relief as deemed just and appropriate in the facts and circumstances of the case. Total

Sh. Shashank Poddar, Jaipur vs. ACIT, Circle-3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 850/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 250Section 57

assessee is prevented in filing the appeal in time and we are satisfied that the delay in filing the appeal is due to reasonable cause. The Ld. DR did not object the application filed by the assessee for the condonation. Thus, the delay of 967 days in filing the appeal

Shri Jitendra Behl, Sriganganagar vs. ITO, Ward-3(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1080/JPR/2024[2017-18]Status: DisposedITAT Jaipur30 Oct 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mrs. Raksha Birla, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT a

Section 143(3)Section 250Section 69A

present dispute and payment of appropriate taxes. Therefore, in the factual matrix of the present case, we find that there exists sufficient and reasonable cause for condoning the delay in filing the present appeal and as held by the Hon'ble Supreme Court, where substantial justice and technical considerations