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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

Rural Development Foundation, Anand vs. CPC, Bengaluru Juris. AO- the ITO, Ward-Exemption, Vadodara

In the result, the appeal of the assessee is allowed

ITA 927/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.927/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-20 Rural Development Cpc, Bengaluru बनाम/ Foundation Juris.Ao – The Ito Ward- V/S. Aitc, 2Nd Floor Exemption Narayan Complex Vadodara – 390 007 Nr.Shubh Laxmi Shopping Centre Station Road Anand – 388 001 "थायी लेखा सं./Pan: Aabtr 1090 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Rameshwar P. Meena, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/10/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has 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 21/02/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2019-2020. 2. The Assessee Has Raised The Following Grounds Of Appeal: Rural Development Foundation Vs. Cpc, Bengaluru Juris Ao The Ito, Ward-Exemption Asst. Year : 2019-20

For Appellant: Ms. Arti N. Shah, ARFor Respondent: Shri Rameshwar P. Meena, Sr.DR
Section 11Section 12ASection 12A(1)(b)Section 143(1)Section 154Section 250

solely on the ground of procedural lapse in filing the income-tax return and the audit report in Form 10B despite there being a reasonable cause for such lapse. 3. The Hon'ble CIT(A) has erred in law and on facts in not allowing deduction ... filed a rectification petition under section 154 of the Act contending that the delay in filing the return and audit report was due to reasonable cause arising from the serious health condition of its controlling trustee. It was pleaded that the denial of exemption was merely a procedural lapse

Late Tilokchand Kuche Shikshan Prasarak Mandal, Aurangabad vs. CIT Exemption, Pune

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

ITA 534/PUN/2025[NA]Status: DisposedITAT Pune29 Oct 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.534/Pun/2025 निर्धारण वषा / Assessment Year: - Late Tilokchand Kuche V Commissioner Of Income Shikshan Prasarak Mandal, S. Tax, Exemption Pune. Plot No.17, Laxmidevi Balaji Mandir, Juni Mukundwadi, Aurangabad – 431001. Pan: Aabtl3131C Appellant/ Assessee Respondent / Revenue Assessee By Shri Vijay B. Ambhore Revenue By Shri Amit Bobde Date Of Hearing 15/10/2025 Date Of Pronouncement 29/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Application For Grant Of Registration Under Section 80G Of The Income Tax Act, 1961 Dated 09.12.2024. The Assessee Has Raised Following Grounds Of Appeal : “1. The Learned Commissioner Of Income Tax Exemption Erred In Rejecting The Application For Regular Approval U/S 80G(5) Of The Income Tax Act In An Arbitrary Manner.

Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

purpose. ITA No.534/PUN/2025 [A] 3. There was a delay of 22 days in filing appeal. We are satisfied that there was a sufficient and reasonable cause for delay, hence, the Delay is condoned. 4. In the result, appeal of the Assessee is allowed for statistical purpose. Order pronounced

Shobharam Tulshiram Prajapat, Jalgaon vs. ITO, Ward 1(3), Jalgaon

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

ITA 2128/PUN/2025[2015-16]Status: DisposedITAT Pune29 Oct 2025AY 2015-16

Bench: Dr.Manish Borad

For Appellant: Shri Vinay KawdiaFor Respondent: Shri Ajitesh Meena
Section 143(2)Section 144Section 147Section 148Section 153CSection 69A

afford reasonable opportunity of hearing to the assessee. 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. 8. In the result, the appeal filed by the assessee is allowed

Yetchina Srinivas, Bilaspur vs. DCIT, Circle, 1(1), Pune

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

ITA 1904/PUN/2025[2018-19]Status: DisposedITAT Pune29 Oct 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Shri Sachin KumarFor Respondent: Shri Ajitesh Meena
Section 142(1)Section 143(3)Section 8Section 80CSection 8O

Pune, the delay has arisen and therefore the assessee could not file the appeal within the prescribed time limit. I am satisfied that ‘reasonable cause’ prevented the assessee to file the appeal within the stipulated time. However, in the larger interest of justice adopting justice oriented approach and taking guidance ... ld.JAO shall grant reasonable opportunity to the assessee. 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

Tangmarg Investment and Trading Pvt.Ltd, Pune vs. ACIT, Circle-7, Pune

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

ITA 1878/PUN/2025[2017-18]Status: DisposedITAT Pune29 Oct 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1878/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Bharat Andhale
Section 143(2)Section 144Section 249(2)

before this Tribunal. Assessee has filed an affidavit explaining the delay. 3. On perusing the averments made in the Affidavit, we are satisfied that ‘reasonable cause’ prevented the assessee to file the appeal within the stipulated time. We note that the delay is not intentional and assessee would not have ... appeal has been dismissed in limine and not found in conformity with the provisions of section 249(2) of the Act. He submitted that ‘reasonable cause’ prevented the assessee from filing an appeal before ld.CIT(A) in the prescribed time limit. He therefore prayed that delay in filing of appeal

Machhindra Ishwarchand Sarode, Pune vs. Income Tax Officer, Ward Thirteen(Four), Pune

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

ITA 1746/PUN/2025[2018-19]Status: DisposedITAT Pune29 Oct 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Ajitesh Meena
Section 147Section 148Section 250(6)Section 56(2)(x)

afford reasonable opportunity of hearing to the assessee. 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. 7. In the result, the appeal filed by the assessee is allowed

Balkrishna Dnyanoba Khandve, Pune vs. Central Circle 2(3), Pune

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

ITA 2495/PUN/2024[2015-2016]Status: DisposedITAT Pune29 Oct 2025AY 2015-2016

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2495/Pun/2024 Assessment Year : 2015-16

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ramnath P. Murkunde
Section 133ASection 147Section 148Section 37Section 40A(3)Section 40a

before this Tribunal. Assessee has filed an affidavit explaining the delay. 3. On perusing the averments made in the Affidavit, we are satisfied that ‘reasonable cause’ prevented the assessee to file the appeal within the stipulated time. We note that the delay is not intentional and assessee would not have ... shall grant reasonable opportunity to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside 4 Balkrishna Dnyanoba Khandve and the effective grounds raised by the assessee are allowed for statistical purposes

Madhavi Beeravolu, Hyderabad vs. Income Tax Officer, Ward-8(1), Signature Towers

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

ITA 1154/HYD/2025[2018-19]Status: DisposedITAT Hyderabad29 Oct 2025AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 69A

appeal of assessee on account of delay in filing the appeal before the learned CIT(A), although, the assessee has explained ‘sufficient and reasonable cause’. He, therefore, submitted that, in the interest of justice, the matter may be set-aside to the file of learned CIT(A) for afresh adjudication

Sangeeta Akkaraju Chandrasekhar, Hyderabad vs. ITO., Ward-14(1), Hyderabad

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

ITA 1076/HYD/2025[2017-18]Status: DisposedITAT Hyderabad29 Oct 2025AY 2017-18

Bench: The Tribunal. The Assessee Has Filed An Affidavit In Support Of The Condonation Petition, Wherein She Has Mentioned The Reasons For The Delay & Submitted That The Delay Occurred Due To Factors Beyond Her Control, With No Deliberate Intention To Defer The Filing Of The Appeal. On The Other Hand, The Learned Senior A.R. For The Revenue, Shri Mathivanan, S.A. Did Not Strongly Oppose The Condonation Of Delay Petition Filed By The Assessee.

Section 142(1)Section 147Section 148Section 194ASection 80CSection 80T

considered view that, the reasons given by the assessee for not filing the appeal within the time allowed under the Act, come under reasonable cause as provided under the Act for condonation of delay. We further find that, the Hon’ble Supreme Court in the case of Collector, Land Acquisition

Ravi Vijayalakshmi, Athipattu vs. ITO, Nc2-6(1), Chennai

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

ITA 2518/CHNY/2024[2016-17]Status: DisposedITAT Chennai29 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.2518/Chny/2024 िनधा"रण वष"/Assessment Year: 2016-17 Ravi Vijayalakshmi, Vs. The Income Tax Officer, 211/A 211A, Rs Road, Reddipalayam, Non Corporate Ward 6(1), Athipattu 600 120, Tamil Nadu. Chennai. [Pan:Akbpv5530B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 29.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.01.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. We Find That This Appeal Is Filed With A Delay Of 180 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144

appeal. 5. The ld. AR Shri Y. Sridhar, F.C.A., referring to statement of facts Sl.No. 9, submits that the assessee has furnished the reasonable cause for the delay in filing the appeal in Form 35. He drew our attention to para 2 of the impugned order and submits that ... both the parties and perused the material available on record. On perusal of Col. 15 of Form 35, we note that the assessee furnished reasonable cause for the delay in filing the appeal. In para 2 of the impugned order, the ld. CIT(A) has reproduced the reasonable cause

Shri. G K Ravi, Bangalore vs. ACIT, Central Circle-1(4), Bengaluru

ITA 2269/BANG/2024[2018-19]Status: DisposedITAT Bangalore29 Oct 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Shri. G K Ravi, Bangalore vs. ACIT, Central Circle-1(4), Bengaluru

ITA 2268/BANG/2024[2017-18]Status: DisposedITAT Bangalore29 Oct 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Shri. G K Ravi, Bangalore vs. ACIT, Central Circle-1(4), Bengaluru

ITA 2267/BANG/2024[2016-17]Status: DisposedITAT Bangalore29 Oct 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Shri. G K Ravi, Bengaluru vs. ACIT, Central Circle-1(4), Bengaluru

ITA 2266/BANG/2024[2015-16]Status: DisposedITAT Bangalore29 Oct 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Si. No. 1. 2. 3. 4. 5. 6. 7. 8.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Shri. G K Ravi, Bengaluru vs. ACIT, Central Circle-1(4), Bengaluru

ITA 2265/BANG/2024[2014-15]Status: DisposedITAT Bangalore29 Oct 2025AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Shri. G. K Ravi, Bangalore vs. ACIT/DCIT, Central Circle-1(4), Bangalore

ITA 2264/BANG/2024[2013-14]Status: DisposedITAT Bangalore29 Oct 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Gottigere Krishnappa Ravi, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

ITA 1159/BANG/2024[2019-20]Status: DisposedITAT Bangalore29 Oct 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Yuvak Prerna Foundation, Mumabai vs. Commissioner of Income Tax (Exemptions), Mumbai

In the result, both the appeals in ITA Nos

ITA 5182/MUM/2025[NA]Status: DisposedITAT Mumbai29 Oct 2025

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Ms. Kinjal Bhuta, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 11Section 12ASection 12A(1)(ac)Section 80G

filing of Form 10AB. However, the ld.CIT(E) rejected the plea as oversight and unawareness about tax compliances could not be considered as reasonable cause for delay for filing of Form 10AB. It was further observed that the 'due date' of filing application on or before ... file/re- file their applications under certain conditions. However, the applicant failed to avail the benefit of the same. As it failed to show any reasonable cause for delay or to establish that it had genuine hardship in filing of the application within the due date, the request of the applicant

Yuvak Prerna Foundation, Mumbai vs. Commissioner of Income Tax (Exemptions) Mumbai, Mumbai

In the result, both the appeals in ITA Nos

ITA 5181/MUM/2025[NA]Status: DisposedITAT Mumbai29 Oct 2025

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Ms. Kinjal Bhuta, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 11Section 12ASection 12A(1)(ac)Section 80G

filing of Form 10AB. However, the ld.CIT(E) rejected the plea as oversight and unawareness about tax compliances could not be considered as reasonable cause for delay for filing of Form 10AB. It was further observed that the 'due date' of filing application on or before ... file/re- file their applications under certain conditions. However, the applicant failed to avail the benefit of the same. As it failed to show any reasonable cause for delay or to establish that it had genuine hardship in filing of the application within the due date, the request of the applicant

Sewa Sahakari Samiti Maryadit, Datia vs. ITO Ward 2(3)(3), Jhansi

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

ITA 404/AGR/2025[2017-18]Status: DisposedITAT Agra28 Oct 2025AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Sunil Kumar Singhsewa Sahakari Samiti Maryadit, Vs. Ito, Ward 2(3)(3), (Alias Prathmik Krishi Sakh Sahkari Jhansi. Samiti Maryadit Indergarh), Gram Indragarh Datia, Datia– 475 661 (Madhya Pradesh) . (Pan : Aawfs2482G) (Appellant) (Respondent) Assessee By : None Revenue By : Shri Shailendra Srivastava, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Order : 28.10.2025 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 25.11.2024 For The Assessment Year 2017-18. 2. None Appeared On Behalf Of The Assessee. We Are Proceeding To Adjudicate The Matter With The Assistance Of Ld. Dr Of The Revenue.

For Appellant: NoneFor Respondent: Shri Shailendra Srivastava, Sr. DR

application for condonation of delay. After going through the application for condonation of delay, we observe that there was a reasonable cause in filing the appeal belatedly and accordingly, we are inclined to condone the delay. 6. Further on merits of the appeal, at the time of hearing, we observe