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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

Tata Education Trust, Mumbai vs. ACIT-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4156/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w Shri Sukhsagar & Shri Atul SuraiyaFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

filing the appeal. After considering the submissions of learned DR, we are satisfied that the delay in filing the appeal was due to reasonable cause. Hence we condone the delay and admit the appeal for adjudication. 22. We have heard the parties and perused the materials on record. After carefully

Eradicatus Infectus Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

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

ITA 92/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Oct 2025AY 2022-23

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(1)Section 80I

delay had occurred, therefore, it is prayed to condone the delay. After considering the submissions of the assessee, we find that there is a reasonable cause in filing the appeal delayed as appeal was already filed in time before the ITAT, Chandigarh Bench in terms of the acknowledgement no.1727683840 dated

Rajesh Bubna, Delhi vs. ACIT, Central Circle- 20, Delhi

In the result, the appeal of the assessee is allowed

ITA 1424/DEL/2023[2019-20]Status: DisposedITAT Delhi10 Oct 2025AY 2019-20

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 132(4)Section 143(3)Section 69A

erred in law and on facts by not admitting Additional Evidence filed under Rule 46A of the IT Rules 1962 without considering the reasonable cause mentioned therein. 4. That the Ld. CIT(A) has erred in law and on facts in not providing the Appellant with the reasonable opportunity

Grishmaben Ojasbhai Patel, Surat vs. ITO 3(2) (1), Surat

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

ITA 914/SRT/2025[2011-12]Status: HeardITAT Surat09 Oct 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250Section 271(1)(c)

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 AO and Ld. CIT(A). Hence the Bench is of the view that one more

Varshaben Jayantibhai Trada, Utran vs. DCIT, Circle 2(1) (1), Surat

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

ITA 913/SRT/2025[2018-19]Status: HeardITAT Surat09 Oct 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

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 Ld. CIT(A). Hence the Bench is of the view that one more opportunity

Shree Kailash Stone Quarry (Firm), Surat vs. National E-Assessment Centre, Delhi

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

ITA 886/SRT/2025[2022-23]Status: HeardITAT Surat09 Oct 2025AY 2022-23

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

assessee and taking into consideration the facts narrated before us and while taking a lenient view that, we find 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 be given

Ashvinbhai Laxmanbhai Karkar, Surat vs. ITO, Ward 3(1)(5), Surat

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

ITA 83/SRT/2025[2016-17]Status: HeardITAT Surat09 Oct 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 144Section 250Section 271(1)(c)

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. Hence the Bench is of the view that one more opportunity

Ashvinbhai Laxmanbhai Karkar, Surat vs. ITO, Ward 3(1)(5), Surat

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

ITA 82/SRT/2025[2016-17]Status: HeardITAT Surat09 Oct 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 144Section 250Section 271(1)(c)

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. Hence the Bench is of the view that one more opportunity

Kamlesh Kantilal Gandhi, Adajan vs. Ward 3(2)(6), Surat, Adajan

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

ITA 592/SRT/2025[2011-12]Status: HeardITAT Surat09 Oct 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 148Section 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 AO and Ld. CIT(A). Hence the Bench is of the view that one more

Vishakhaben Jigarbhai Nayak, Surat vs. ITO, Ward 2(3)(4), Surat

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

ITA 550/SRT/2025[2012-13]Status: HeardITAT Surat09 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

other hand Ld. DR contested the plea raised by the assessee and submitted that assessee had not cooperated intentionally and without reasonable cause and thus relied upon the orders passed by the revenue authorities. 5. Be that as it may, without going into the merits of the issues raised ... 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 be given to the assessee to represent her case before revenue authorities. Therefore considering the overall

Deepak Balraj Narang, Surat vs. DCIT Circle 1(3), Surat

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

ITA 526/SRT/2025[2015-16]Status: HeardITAT Surat09 Oct 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

issues raised by the assessee and taking into consideration of the facts narrated before us and while taking a lenient view 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

Neeru Deepak Narang, Surat vs. DCIT Circle 1(3), Surat

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

ITA 525/SRT/2025[2014-15]Status: HeardITAT Surat09 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

issues raised by the assessee and taking into consideration of the facts narrated before us and while taking a lenient view 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

Domadia Raiyaben Muljibhai Charitable Trust, Surat vs. ITO, Exemption Ward, Surat

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

ITA 5/SRT/2025[2016-17]Status: HeardITAT Surat09 Oct 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

request is attached). However, CIT(A) had not considered the Adjournment request and passed an ex- party order on 27/11/2024. Kindly consider it as reasonable cause in not complying with the appellate proceedings as the assessee was prevented from making submission. I kindly request your Honour to admit this appeal ... into consideration of the facts narrated before us and while taking a lenient 3 Domadia Raiyaben Muljibhai Charitable Trust, Surat view 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

Thakorbhai Chhaganbhai Mori, Bharuch vs. ITO, Ward 1(1), Bharuch

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

ITA 405/SRT/2025[2012-13]Status: HeardITAT Surat09 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 143(3)Section 250Section 253Section 271(1)(c)Section 5

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

Brijwasi Developers Private Limited, Surat vs. ACIT, Circle 1(1)(1), Surat

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

ITA 280/SRT/2025[2008-09]Status: HeardITAT Surat09 Oct 2025AY 2008-09

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

construed on the basis of date of order, the delay in filing the appeal was not intentional and assessee was prevented by sufficient and reasonable cause for not filing the appeal in time. 3 Brijwasi Developers Pvt Ltd, Surat. 6) I beg to condone the delay in filing the appeal ... 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

Maniben Dalpatbhai Patel, Surat vs. ITO, Ward 2(2)(1), Surat

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

ITA 157/SRT/2025[2013-14]Status: HeardITAT Surat09 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 250

therefore 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 AO and Ld. CIT(A). Hence the Bench is of the view that one more opportunity be given

Nitaben Girishbhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(2), Ahmedabad

In the result, while upholding the validity of reopening, we set aside the ex parte order of the CIT(A) on merits and restore the matter to his file for fresh adjudication in accordance with law

ITA 1560/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Nitaben Girishbhai Patel The Ito, Ward-3(3)(2) 33/B, Swi Park, Private Plot Vejalpur Madhuvrund Society Ahmedabad. Ghatlodiya, Ahmedabad. Pan : Aappp 5738 F (Applicant) (Responent) : Shri Parimalsinh B. Parmar, Ar Assessee By : Shri B.P. Srivastava, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri B.P. Srivastava, Sr.DR
Section 144BSection 147Section 148Section 271ASection 69A

proceeded to dismiss the appeal ex parte. The assessee has further affirmed that the non-compliance was not willful but was due to a reasonable cause, namely the oversight in forwarding the notices. 3.1 The learned AR of the assessee further contended that the reasons recorded for reopening specifically alleged ... statements. The explanation tendered in the affidavit, namely that notices issued by the CIT(A) were inadvertently not forwarded to the Chartered Accountant, constitutes reasonable cause. In our considered view, the evidences now produced are vital and decisive for determining the controversy. 5.5 Considering the totality of circumstances

Assistant Commissioner of Income Tax, Circle-1(1)(1), Vadodara vs. Baroda Gujarat Gramin Bank, Vadodara

In the result, the appeal filed by the Revenue fails on the sole

ITA 1251/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal

For Appellant: Shri Mukund Rao, AR
Section 143(1)Section 250Section 36(1)(va)Section 37Section 41(1)

disassociate from EPFO and establish their own Provident Fund Trust, and accordingly the payment was made in June 2020; hence there was a reasonable cause and no disallowance was warranted. 2.8 The Learned CIT(A) considered the submissions and adjudicated on each of the issues

Rajendraa Sakunthala, Coimbatore vs. ACIT, Ncc-2, Coimbatore

In the result, appeal filed by the assessee is allowed

ITA 1624/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Oct 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. Sudharshan, Advocate for Shri. S. Sridhar, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 139(1)Section 147Section 148Section 148ASection 50C

perusal of the affidavit and after affording due opportunity of hearing to both parties, we are satisfied that the assessee has demonstrated sufficient and reasonable cause for not presenting the appeal within the statutory period prescribed under law. Accordingly, in the interest of justice, the delay in filing the appeal

Sri Tippeswamy Trading Company, Byadgi vs. Income Tax Officer, Ward-2, Haveri

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

ITA 1149/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Year: 2016-17

For Appellant: Shri R Chandrashekar, AdvocateFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

from the erstwhile Tax Advocate and file the appeal. 2.2 The delay of 688 days, in our view, was occurred due to sufficient and reasonable cause. The illness and subsequent demise of the consultant were circumstances beyond the control of the assessee. The delay is therefore condoned. 2.3 On merits