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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

Jalgaon Jilha Sahakari Cottan Marketing Fedration, Jalgaon vs. ITO, Ward1(4), Jalgaon

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

ITA 616/PUN/2025[2018-19]Status: DisposedITAT Pune24 Sept 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.616/Pun/2025 धििेंारण वर्ा /Assessment Year: 2018-2019 Jalgaon Jilha Sahakari Ito, Ward 1(4), Cotton Marketing Jalgaon Fedration Limited, 135/1, Vs. Jilha Peth, Near S.B.I., Jalgaon-425001 Maharashtra Pan-Aadfj8195Q अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Smt. Deepa Khare Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 30.01.2025 Which Is Arising Out Of Order Passed U/S 143(3) Of The Act Dated 10.02.2021. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. The Learned Cit(A) Has Erred On Facts & In Law In Confirming The Disallowance Of Deduction U/S 80P(2)(A)(Iv) Without Appreciating The Facts & Circumstances Of The Case. 2. The Learned Cit(A) Has Erred On Facts & In Law In Not Appreciating That The Non- Compliance Was Reasons Beyond The Control Of The Appellant. The Appellant Prays That Opportunity May Kindly Be Provided To Explain Its Case.

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 143(3)Section 250Section 80P(2)(a)

hearing shall be granted to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. 7. In the result appeal of the assessee is allowed for statistical

Ashok Gurunath Patil, Latur vs. ITO Ward1(1), Latur

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

ITA 594/PUN/2025[2011-12]Status: DisposedITAT Pune24 Sept 2025AY 2011-12

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.594/Pun/2025 धििेंारण वर्ा /Assessment Year: 2011-2012 Ashok Gurunath Patil, Ito, Ward 1(1), Latur A/P Masobavadi, Khed, Nilanga, Latur-413522 Vs. Maharashtra Pan-Bihpp0618K अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Pratik Sandbhor Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 21.08.2024 Which Is Arising Out Of Order Passed U/S 271(1)(C) Of The Act Dated 27.02.2018. 2. Registry Has Informed That There Is A Delay Of 123 Days In Filing Of The Appeal. Application For Condonation Of Delay Alongwith Affidavit Has Been Filed & Placed At Page No. 24-26 Of The Appeal Citing The Main Reason For The Delay, That The Assessee Was Not Aware Of Passing Of The Impugned Order As 2 The Tax Consultant Registered The E-Mail Id Of His Younger Son & The E-Mail Account Was Not In Use. After Hearing The Ld. Departmental Representative (Dr) & Perusing The Records We Find That The Sufficient Cause Prevented The Assessee From Filing The Appeal Within The Prescribed Time Limit & The Delay Is Not Intentional. Therefore In The Larger Interest Of Justice & Also Placing Reliance On The Judgement Of Hon’Ble Apex Court In The Case Of Collector, Land Acquisition Vs. Master Katiji & Others(1987) 167 Itr 471(Sc) (Supreme Court) & In The Case Of Inder Singh Vs State Of Madhya Pradesh Judgement Dated 21.03.2025 (2025) Insc 382) We Hereby Condone The Delay Of 123 Days & Admit The Appeal For Adjudication On Merits.

For Appellant: Shri Pratik SandbhorFor Respondent: Shri Ramnath P Murkunde
Section 250Section 271(1)(c)Section 274

hearing shall be granted to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. 8. In the result appeal of the assessee is allowed for statistical

Adm Foundation, Pune vs. Commissioner of Income Tax(Exemption), Pune

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

ITA 2084/PUN/2025[2026-27]Status: DisposedITAT Pune24 Sept 2025AY 2026-27

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2084/Pun/2025 निर्धारण वषा / Assessment Year: N.A. Adm Foundation, V The Commissioner Of 7Th Office No.703, Floor, S Income Tax(Exemption) Tower-2, Montreal Business Center, Baner, Murkutenagar, Pune – 411045. Pan: Aarca5387Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Nemin Shah & Ms.Smruti Sabnis Revenue By Shri Aditya Shukla – Cit(Dr) Date Of Hearing 18/09/2025 Date Of Pronouncement 24/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Application Under Section 80G Of The Income Tax Act, 1961, Dated 30.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : Ground 1. Learned Cit(Exemption), Pune Has Erred In Rejecting The Application Made Under Section 80G(5)(Ii) Of The Income Tax Act, 1961 Vide Order Dated 30Th August 2025. Ita No.2084/Pun/2025 [A]

Section 12ASection 8Section 80GSection 80G(5)Section 80G(5)(ii)

delay in filing Form 10AB without appreciating that the delay was due to technical glitch on the income tax portal which constitutes sufficient and reasonable cause for the delay. Ground 3. The appellant craves leave to add, alter, vary, omit, amend, or delete the above grounds of appeal

Nikhil Baban Nimbalkar, Pune vs. ITO, Ward 14(5), Pune

In the result both appeals of the assessee are allowed for statistical purposes

ITA 2526/PUN/2024[2019-20]Status: DisposedITAT Pune24 Sept 2025AY 2019-20

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.2525&2526/Pun/2024 धििेंारण वर्ा /Assessment Year: 2018-2019 & 2019-2020 Nikhil Baban Nimbalkar, Ito, Ward 14(5), Nimbalkar Hospital, Patas Pune Road, Baramati, Pune- Vs. 413102 Maharashtra Pan-Ajdpn1546Q अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Pratik Sandbhor Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 04.10.2024 Which Is Arising Out Of Order Passed U/S 147 R.W.S 144 Of The Act Dated 29.02.2024. 2. Assessee Has Raised Following Grounds Of Appeal In Ita No. 2525/Pun/2024:- 1. On The Facts & In The Circumstances Of The Case & In Law The Id. Cit(A) Erred In Not Granting Sufficient Opportunities Of Hearing & Dismissing The Appeal Ex-Parte 2. On The Facts & In The Circumstances Of The Case & In Law The Appellant Prays Before The Hon'Ble Bench To Kindly Grant An Opportunity To Represent The Matter Before The Ld Cit(A).

For Appellant: Shri Pratik SandbhorFor Respondent: Shri Ramnath P Murkunde
Section 147Section 148Section 250Section 404(3)

hearing shall be given to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee in ITA No. 2525/PUN/2024 and ITA No. 2526/PUN/2024 are allowed for statistical purposes. 7. In the result

Nikhil Baban Nimbalkar, Pune vs. ITO, Ward 14(5), Pune

In the result both appeals of the assessee are allowed for statistical purposes

ITA 2525/PUN/2024[2018-19]Status: DisposedITAT Pune24 Sept 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.2525&2526/Pun/2024 धििेंारण वर्ा /Assessment Year: 2018-2019 & 2019-2020 Nikhil Baban Nimbalkar, Ito, Ward 14(5), Nimbalkar Hospital, Patas Pune Road, Baramati, Pune- Vs. 413102 Maharashtra Pan-Ajdpn1546Q अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Pratik Sandbhor Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 04.10.2024 Which Is Arising Out Of Order Passed U/S 147 R.W.S 144 Of The Act Dated 29.02.2024. 2. Assessee Has Raised Following Grounds Of Appeal In Ita No. 2525/Pun/2024:- 1. On The Facts & In The Circumstances Of The Case & In Law The Id. Cit(A) Erred In Not Granting Sufficient Opportunities Of Hearing & Dismissing The Appeal Ex-Parte 2. On The Facts & In The Circumstances Of The Case & In Law The Appellant Prays Before The Hon'Ble Bench To Kindly Grant An Opportunity To Represent The Matter Before The Ld Cit(A).

For Appellant: Shri Pratik SandbhorFor Respondent: Shri Ramnath P Murkunde
Section 147Section 148Section 250Section 404(3)

hearing shall be given to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee in ITA No. 2525/PUN/2024 and ITA No. 2526/PUN/2024 are allowed for statistical purposes. 7. In the result

Devraj Vishwasrao Jadhav, Pune vs. Income Tax Officer, Ward-3, Satara

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

ITA 2213/PUN/2024[2015-16]Status: DisposedITAT Pune23 Sept 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / .Ita No.2213/Pun/2024 धििेंारण वर्ा /Assessment Year: 2015-2016 Devraj Vishwasrao Ito, Ward-3, Satara Jadhav, R. No. 06, S. No. 24, Vs. Dreams Rhythm, Opposite Talathi Office, Bavdhan, Pune-411021 Maharashtra Pan-Aebpj6968F अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Dr. Prayag Jha Department By: Shri Ramnath P Murkunde Date Of Hearing: 23-09-2025 Date Of Pronouncement: 08-09-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 11.09.2024 Which Is Arising Out Of Order Passed U/S 147 Of The Act Dated 14.03.2023. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. The Ld Cit(A) Erred In Not Considering The Arguments & Submissions Made By The Assessee & Dismissing All The Grounds Taken In Appeal. 2. The Ld Cit(A) Erred In Not Appreciating That The Ld Assessing Officer Had Not Served On The Assessee The Statutory Notice Under Section 143(2) Of The It Act & Therefore, The Impugned Order Was Passed Without Jurisdiction.

For Appellant: Dr. Prayag JhaFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 147Section 148Section 148ASection 250Section 68Section 69A

hearing shall be granted to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Grounds of appeal raised by the assessee are allowed for statistical purposes. 10. In the result, appeal of the assessee is allowed for statistical purposes

Mrt No.1 Charitable Trust, Chennai vs. ITO, Exemptions, Chennai

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

ITA 1934/CHNY/2025[-]Status: DisposedITAT Chennai23 Sept 2025

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. Nos.1933 & 1934/Chny/2025 Mrt No. 1 Charitable Trust, Vs. The Commissioner Income No. 16, Krishnama Road, (Exemption), Nungambakkam, Chennai 600 034. Chennai. [Pan:Aabtm7859A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/ Date Of Hearing : 18.09.2025 घोषणा की तारीख /Date Of Pronouncement : 23.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1933/Chny/2025 Filed By The Assessee Is Directed Against Order Dated 06.04.2022 Passed By The Ld. Pcit/Cit, Chennai In Form No. 10Ac Granting Provisional Approval Under Section 80G(5)(Iv) & 80G(5)(Iii) Of The Income Tax Act, 1961 [“Act” In Short]. The Appeal In Ita No. 1934/Chny/2025 Filed By The Assessee Is Directed Against The Order Dated 09.06.2025 By The Ld. Cit(Exemption), Chennai Rejecting Approval Under Section 80G(5)(Iii) Of The Act.

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)

complexities involved in understanding and implementing the provisions governing the transition of old regime to new regime which would constitute reasonable cause for admission of appeal for adjudication of issues on merits in the interest of justice. 5. Upon hearing both the parties and on examination of the said affidavit