“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

District Co-Opertive Sugar Cane Supply Ltd., Bareilly vs. ITO Range-1(1), Bareilly

In the result, in the combined result in ITA

ITA 578/LKW/2024[2018-19]Status: DisposedITAT Lucknow30 Oct 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(3)Section 154Section 80P

contrary, the Ld. Departmental Representative opposed the submissions of the Ld. Counsel for the assessee and contended that there was no reasonable cause for filing the present appeal belatedly. He, therefore, contended that the appeal deserves to be dismissed on the ground of the limitation alone. ITA. Nos. 577 & 578/LKW/2024 ... contrary, the Ld. Departmental Representative opposed the submissions of the Ld. Counsel for the assessee and contended that there was no reasonable cause for filing the present appeal belatedly. He, therefore, contended that the appeal deserves to be dismissed on the ground of the limitation. 17. Heard the Ld. Representatives

District Co-Opertive Sugar Cane Supply Ltd, Bareilly vs. ITO Range-1(2), Bareilly

ITA 577/LKW/2024[2016-17]Status: DisposedITAT Lucknow30 Oct 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(3)Section 154Section 80P

Shri Murli Manohar Nagari Sahakari Patsanstha Maryadit, Mahad vs. Income-Tax Officer, Panvel

In the result, appeal of the assessee is partly allowed

ITA 934/PUN/2025[2017-18]Status: DisposedITAT Pune30 Oct 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.934/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Shri Murli Manohar Nagari V Income Tax Officer. Sahakaripatsansthamaryadit, S. 1295, Pimpal Par, M.G.Road, Juni Peth, Mahad, Mahad – 402301. Maharashtra. Pan: Aabas5404L Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Shaha Revenue By Shri Dayanand Jawalikar–Addl.Cit(Dr) Date Of Hearing 14/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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.2017-18, Dated 11.03.2024 Emanating From Assessment Order U/S.143(3) R.W.S 263 Read With Section 144B Of The I.T.Act, Dated 17.03.2023. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(2)Section 143(3)Section 144BSection 250Section 263Section 80PSection 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. We have heard both the parties and perused the records. In this case, Assessee

Kapil Chamanlal Setia, Dhule vs. Addl/Joint/Dy/Asst.CIT/ITO, Itd, National Faceless Assessment Centre, Delhi

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

ITA 810/PUN/2025[2018-19]Status: DisposedITAT Pune30 Oct 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.810/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Sharad ShahFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 250

pass a speaking order. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds raised by the assessee are allowed for statistical purposes. 9. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced

Tejas Shivaji Adsul, Kolhapur vs. Income Tax Officer Ward 1(1), Kolhapur

In the result, appeal of the assessee is allowed

ITA 59/PUN/2025[2018-19]Status: DisposedITAT Pune30 Oct 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri A.R. Naik (Virtual)For Respondent: Shri Akhilesh Srivastva

Section 115JSection 143Section 147Section 148Section 270ASection 270A(6)

facts and circumstances, I am satisfied that the assessee committed default of under reporting of income in consequence of mis-reporting of income without reasonable cause. I am also satisfied that, this is fit case for levy of penalty u/s 2 of the Act. The penalty is leviable in respect

Amit Suresh Agrawal, Satara vs. ITO Ward-2, Satara

In the result, appeal of the assessee is partly allowed

ITA 2225/PUN/2025[2016-17]Status: DisposedITAT Pune30 Oct 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 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 The A.Y.2016-17 Dated 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149(1)(b)Section 151Section 151ASection 153ASection 153CSection 250Section 271(1)(c)Section 68

There was delay of 91 days. Assessee filed an Affidavit. We have perused the Affidavit and are convinced that there is sufficient and reasonable cause for delay. Hence, the Delay is condoned. 11 ITA No.2225/PUN/2025 [A] 10. In the result, appeal of the assessee is partly allowed. Order pronounced

Satyamev Nagari Sahakari Patsanstha Maryadit, Nashik vs. Income Tax Officer - Ward 1(1), Nashik

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

ITA 2036/PUN/2025[2021-22]Status: DisposedITAT Pune30 Oct 2025AY 2021-22

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2036/Pun/2025 निर्धारण वषा / Assessment Year: 2021-22 Satyamev Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S Ward-1(1), Nashik. 1, Maratha Tower, Raviwar Karanja, Nashik – 422001. Maharashtra. Pan: Aakas2833C Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 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 The A.Y.2021-22 Dated 17.06.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated

Section 147Section 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 80P

High Court in Premkumar Arjundas Luthra ((2017) 297 CTR 614]. 2] Without prejudice to the above ground, the appellant submits that there was a reasonable cause due to which proper compliance could not be made before the A.O. in the course of the faceless asst. proceedings conducted during Covid period ... opportunity of being heard, in the interest of justice. 31 and Without prejudice to the above grounds, the appellant submits that there was a reasonable cause due to which the notices of hearing issued by the CIT(A) could not be complied with, in as much as, the notice

Dhanbir Suri, Mumbai vs. ITO Ward 28(1)(1), Mumbai

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

ITA 5370/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosaina.Ys: 2017-18

Section 250

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 the revenue authorities. The Bench is of the view that one more opportunity be given

Smt. Sobha Rani, Delhi vs. The Income Tax Officer Ward 35(1), Delhi

In the result the appeal of the assessee is allowed

ITA 5429/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18

For Appellant: Shri Yudhistet Mehtani, CA &For Respondent: Shri Manoj Kumar, Sr. DR

Section 147Section 148Section 148ASection 149(1)(a)Section 149(1)(b)

filing the appeal before the Tribunal. Upon hearing the parties and perusing the records, I am of the considered view that reasonable cause has been attributed to the assessee in filing the appeal, hence, I condone the delay of 1 day and proceed further. 4. The assessee has raised

Cryptographic It Solutions Private Limited, Delhi vs. DCIT Circle 4(2), C R Building

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

ITA 4075/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Oct 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh

Section 147Section 148Section 5

been filed along with memorandum of appeal. 7. That the impugned appeal is thus delayed on account of the reasons mentioned hereinabove which constitute reasonable cause and the delay cannot be deemed to be wilful nor unreasonable. The delay deserves to be condoned and the appeal deserves to be admitted

Shri Antriksh Gupta, Delhi vs. ITO Ward-35(4), Delhi

In the result, both appeals of the assessee are allowed as above

ITA 2421/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 271ASection 271B

271A of the Act to the extent of INR 25,000/-. Here, the defense taken by the assessee is only Sh. Antriksh Gupta the reasonable cause; the belief that the surplus/commission income derived from sale of Amul Dairy Products is the business receipts of the assessee. Since this year ... obligation. We therefore, considering facts of the case and above referred case laws, are of the considered view that the assessee has reasonable cause for not maintaining books of accounts. Therefore; as a one-time measure, we hereby delete the penalty levied under section 271A of the Act. The assessee

Shri Antriksh Gupta, Delhi vs. ITO Ward-35(4), Delhi

In the result, both appeals of the assessee are allowed as above

ITA 2420/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 271ASection 271B

Orchid Corp, Surat vs. ITO, Ward 1(1)(1), Surat

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

ITA 1119/SRT/2024[2021-22]Status: DisposedITAT Surat29 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1119/Srt/2024 Assessment Year: (2021-22) (Hybrid Hearing) Orchid Corp., Vs. Ito, F-11, Orchid Ventura, Nr. New Lp Ward - 1(1)(1), Savani School, Palanpore Canal Surat Road, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaffo2395F (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 31/07/2025 Date Of Pronouncement 29/10/2025

Section 10B(8)Section 139Section 139(1)Section 143(1)Section 154Section 250Section 80ASection 80I

return. The competent income-tax authorities, while considering an application for condonation, must be satisfied that the tax-payer was prevented by a reasonable cause from filing the return in time and the case involves genuine hardships and reasons beyond control of the assessee. Supporting document is required to substantiate

Lakshmi Narayana Kotha, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, the appeal of the assessee in ITA

ITA 482/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam29 Oct 2025AY 2016-17

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons in all the appeals that, on 24.04.2025, while travelling on a two-wheeler, he slipped and fell, sustaining fracture of the right ankle, and was advised bed rest for fifty days. Thereafter, on 22.06.2025, he was affected with dengue fever and confined to the house for another 2-3 weeks. These unforeseen health circumstances disrupted his regular routine, and in the process of going to the counsel's office for signing th

Section 142(1)Section 147Section 148

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

Lakshmi Narayana Kotha, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, the appeal of the assessee in ITA

ITA 481/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam29 Oct 2025AY 2014-15

Section 142(1)Section 147Section 148

Lakshmi Narayana Kotha, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, the appeal of the assessee in ITA

ITA 480/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam29 Oct 2025AY 2013-14

Section 142(1)Section 147Section 148

Edakkalathur Devassy Daiz, Thrissur vs. ACIT, Circle-2(1), Thrissur

In the result, appeal of the assessee bearing ITA

ITA 651/COCH/2025[2017-18]Status: DisposedITAT Cochin29 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Edakkalathur Devassy Daiz .......... Appellant Edakkalathur House, Ayyanthole P.O. Thriussur 680003 [Pan: Abppd1785R] Vs. Acit, Circle 2(1), Thrissur ......... Respondent Assessee By: Ms. Krishna K., Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: Ms. Krishna K., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 250Section 68

appeal order was also passed exparte. 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 3 Edakkalathur Devassy Daiz Ld. CIT(A) & Ld. AO. It is also evident that during

The Kolkkalam Service Cooperative Bank Limited, Malappuram vs. Income Tax Officer, Ward 1 & Tps, Tirur, Malappuram

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

ITA 650/COCH/2025[2017-18]Status: DisposedITAT Cochin29 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 The Kolkkalam Service Co-Op. Bank Ltd. .......... Appellant Chengannur P.O., Malappuram 676503 [Pan: Aabat8320L] Vs. The Income Tax Officer, Ward-1 &Tps, Tirur ......... Respondent Assessee By: Shri Amaljith, P.J., Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: Shri Amaljith, P.J., 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 5. The Ld. DR argued and stood

Ananthavoor Service Cooperative Bank Ltd, Malappuram vs. Income Tax Officer, Ward 1 & Tps, Tirur, Malappuram

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

ITA 593/COCH/2025[2017-18]Status: DisposedITAT Cochin29 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Ananthavoor Service Co-Op. Bank Ltd. .......... Appellant 13/707, Ananthavoor P.O., Malappuram 676301 [Pan: Aadaa0368F] Vs. The Income Tax Officer, Ward 1 & Tps, Tirur ......... Respondent Assessee By: Shri Amaljith P.J., Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: Shri Amaljith P.J., CAFor Respondent: Smt. Leena Lal, Sr. D.R

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

Kanippayyur Service Co-Operative Bank Ltd, Thrissur vs. Income Tax Officer, Ward-1 & Tps, Guruvayoor, Thrissur

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

ITA 590/COCH/2025[2017-2018]Status: DisposedITAT Cochin29 Oct 2025AY 2017-2018

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Kanippayyur Service Co-Op. Bank Ltd. .......... Appellant Kanippayyur, Thrissur 680517 [Pan: Aabtk8207E] Vs. The Income Tax Officer, Ward 1 & Tps, Guruvayoor..... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

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