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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

No H 1043 Bhujabalapatnam Primary Agriculture Cooperative Credit Society Ltd, Krishna Dist vs. Income Tax Officer, Ward-1, Gudiwada

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

ITA 426/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam17 Oct 2025AY 2017-18

Bench: The Tribunal. The Petitioner/Appellant Society Has Filed An Affidavit Explaining The Reasons For The Delay In Filing The Appeal Before The Tribunal, Wherein It Was Submitted That The Order Passed By The Ld. Cit(A) Was Sent To The Email Of Its Then Ar, Ca B.V. Rao, Instead Of Its Email "Krishnapacs085@Gmail.Com," As Had Been Requested By It. The Appellant Society Came To Know Of The Order Only When Itd Officials Called Upon It To Pay The Tax Arrears. It Further Submitted That, Due To The Above Circumstances Beyond Its Control & Prayed That The Delay Of 69 Days In Filing The Appeal Before The Tribunal May Please Be Condoned In The Interest Of Justice & That The Appeal Be Decided On Merits.

Section 139(1)Section 142(1)Section 144Section 80P(2)(a)

Aparna Villuri, Sr. AR for the Revenue, on the other hand, did not strongly oppose the condonation of delay in view of the reasonable cause explained by the petitioner. 4. We have heard both the parties and perused the petition and affidavit filed by the petitioner seeking condonation of delay ... before the Tribunal. We find that, the reasons explained by the petitioner in its affidavit appear to be genuine and bonafide and come under reasonable cause. We find that, the Hon’ble Supreme Court in the case of Collector, Land Acquisition vs. MST Katiji

Kiran Reddy Muddasani, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, ITA.No.1157/Hyd

ITA 1158/HYD/2025[2012-13]Status: DisposedITAT Hyderabad17 Oct 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1157 & 1158/Hyd./2025 िनधा"रण वष"/Assessment Year 2012-2013 Kiran Reddy Muddasani, The Income Tax Officer, Hyderabad – 500 035. Ward-9(3), Vs. Telangana. Hyderabad – 500 004. Pan Bftpm6705H Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri P. Vinod, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 17.10.2025 आदेश/Order Per Vijay Pal Rao: These Two Appeals Ita Nos.1157 & 1158/Hyd./2025 By The Assessee Are Directed Against The Two Separate Orders Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac”], Delhi, Both Dated 26.05.2025 Arising From Assessment Order Passed U/Sec.147 R.W.S.144 Of The Income

For Appellant: Sri P. Vinod, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 147Section 148Section 271(1)(c)

filing of the appeal before the learned CIT(A) needs to be condoned for both the assessment years because, there is ‘sufficient and reasonable cause’ for the appellant company for not filing the appeals on or before the “due date” provided under the Act. Thus, we condone the delay

Kiran Reddy Muddasani, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, ITA.No.1157/Hyd

ITA 1157/HYD/2025[2012-13]Status: DisposedITAT Hyderabad17 Oct 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1157 & 1158/Hyd./2025 िनधा"रण वष"/Assessment Year 2012-2013 Kiran Reddy Muddasani, The Income Tax Officer, Hyderabad – 500 035. Ward-9(3), Vs. Telangana. Hyderabad – 500 004. Pan Bftpm6705H Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri P. Vinod, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 17.10.2025 आदेश/Order Per Vijay Pal Rao: These Two Appeals Ita Nos.1157 & 1158/Hyd./2025 By The Assessee Are Directed Against The Two Separate Orders Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac”], Delhi, Both Dated 26.05.2025 Arising From Assessment Order Passed U/Sec.147 R.W.S.144 Of The Income

For Appellant: Sri P. Vinod, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 147Section 148Section 271(1)(c)

filing of the appeal before the learned CIT(A) needs to be condoned for both the assessment years because, there is ‘sufficient and reasonable cause’ for the appellant company for not filing the appeals on or before the “due date” provided under the Act. Thus, we condone the delay

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 283/PAT/2025[2018-19]Status: DisposedITAT Patna16 Oct 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

delay. After considering the submissions and I.T.A. Nos.278 to 283/Pat/2025 Aarif Ali material on record, we find that the assessee was prevented by reasonable cause in filing the appeals within the prescribed period. Accordingly, the delay in filing the appeals is condoned, and the appeals are admitted for adjudication

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 282/PAT/2025[2017-18]Status: DisposedITAT Patna16 Oct 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

delay. After considering the submissions and I.T.A. Nos.278 to 283/Pat/2025 Aarif Ali material on record, we find that the assessee was prevented by reasonable cause in filing the appeals within the prescribed period. Accordingly, the delay in filing the appeals is condoned, and the appeals are admitted for adjudication

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 281/PAT/2025[2016-17]Status: DisposedITAT Patna16 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

delay. After considering the submissions and I.T.A. Nos.278 to 283/Pat/2025 Aarif Ali material on record, we find that the assessee was prevented by reasonable cause in filing the appeals within the prescribed period. Accordingly, the delay in filing the appeals is condoned, and the appeals are admitted for adjudication

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 280/PAT/2025[2015-16]Status: DisposedITAT Patna16 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

delay. After considering the submissions and I.T.A. Nos.278 to 283/Pat/2025 Aarif Ali material on record, we find that the assessee was prevented by reasonable cause in filing the appeals within the prescribed period. Accordingly, the delay in filing the appeals is condoned, and the appeals are admitted for adjudication

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 279/PAT/2025[2014-15]Status: DisposedITAT Patna16 Oct 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

delay. After considering the submissions and I.T.A. Nos.278 to 283/Pat/2025 Aarif Ali material on record, we find that the assessee was prevented by reasonable cause in filing the appeals within the prescribed period. Accordingly, the delay in filing the appeals is condoned, and the appeals are admitted for adjudication