“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

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

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

ITA 1933/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

Kanaram Kasaram Choudhary, Mumbai vs. Ward42(1)(3) Mumbai, Mumbai

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

ITA 4549/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Sept 2025AY 2018-19

Bench: Shri Sandeep Gosain

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

Income Tax Officer-42(1)(3), Mumbai vs. Kartik Gunwantrai Shah, Mumbai

In the result, the appeal by the Revenue is allowed for statistical purposes

ITA 2182/MUM/2025[2009-10]Status: DisposedITAT Mumbai23 Sept 2025AY 2009-10

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailincome Tax Officer – 42(1)(3), Room No.735, 7Th Floor Kautilya Bhavan, Bandra Kurla Complex, Bandra (E), ............... Appellant Mumbai - 400051 V/S Kartik Gunwantrai Shah, Prop. Gati Solvochem, B-3, Jalaram, Ganjawala Lane, ……………… Respondent Borivali (West), Mumbai - 400092 Pan : Awaps4637D Assessee By : None Revenue By : Shri Vikas Chandra, Sr.Dr

For Appellant: NoneFor Respondent: Shri Vikas Chandra, Sr.DR

Section 142(1)Section 144Section 147Section 148Section 250Section 46A

various notices issued by the AO. Further, the AO submitted that the assessee has not proved that he was prevented by sufficient and reasonable cause from complying with the notices issued during the assessment proceedings. Accordingly, the AO prayed that the additional evidence filed by the assessee should be rejected

Aneesh Traders, Jvpd Scheme, Mumbai vs. Income Tax Officer Circle 17(1)(1), Mumbai, Kautilya Bhavan

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

ITA 1298/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Sept 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Aneesh Traders, Ito Circle 17(1)(1), 502/504 Dilrag, Presidency Kautilya Bhavan, Society, Jvpd Scheme, Vs. Mumbai-400051. Mumbai-400049. Pan No. Aaafa 1935 G Appellant Respondent

For Appellant: Mr. Surendra Mohan, Sr. DRFor Respondent: Mr. Prateek Jain

Section 142(1)Section 143(2)Section 69A

substantial justice. Where the assessee demonstrates a reasonable substantial justice. Where the assessee demonstrates a reasonable substantial justice. Where the assessee demonstrates a reasonable cause for non-compliance, and expresses readiness compliance, and expresses readiness compliance, and expresses readiness to adduce material evidence, one further opportunity ought to be afforded

Shri Sardar Patel Sarafi Sahkari Mandali Ltd, Bagasara vs. The ITO Ward 3(1)(4), Aayakar Bhavan

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

ITA 560/RJT/2025[2018-19]Status: DisposedITAT Rajkot22 Sept 2025AY 2018-19

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं/.Ita No. 560/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2018-19 Shri Sardar Patel Sarafi Sahkari Income Tax Officer, Wd – Mandali Ltd. Vs. 3(1)(4), Sardar Chowk, Gokul Para, Aayakar Bhavan, Race Course Bagasara - 365440 Ring Road, Rajkot – 360001 Pan No.: Aajas9766K (अपीलाथ"/Assessee) (""यथ"/Respondent) :

For Appellant: Ms. Devina Patel, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(3)Section 250

आयकरअपीलीयअिधकरण,राजकोट"ायपीठ,राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, “SMC” RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT

Arjan Lila Goraniya, Porbandar vs. ITO Ward 2(4), Porbandar

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

ITA 378/RJT/2025[2013-14]Status: DisposedITAT Rajkot22 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainiआयकरअपीलसं आयकरअपीलसं./Ita No.378/Rjt/2025 "नधा"रणवष" "नधा"रणवष" / Assessment Year: (2013-14) Arjan Lila Goraniya Vs. Ito Ward 2 (4), Inajiya Vadi Vistar, Porbandar - 360575 Porbandar Bhojeshwar S.O, Porbandar Bhojeshwar S.O, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./ ./Pan/Gir No.: Bbwpg1554P (Appellant) (Respondent)

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld

Section 144Section 148Section 234ASection 249(4)Section 250Section 271(1)(c)Section 69

assessee cannot be penalize and assessee cannot be penalized for same. This can be considered as for same. This can be considered as reasonable cause to condone to condone the delay. I note that the reasons given in the the reasons given in the affidavit for condonation of delay were

Gajanand Financial Consultancy Private Limited, Nagpur vs. Principal Commissioner of Income Tax (Central) Nagpur, Nagpur

In the result, assessee’s appeal is allowed

ITA 126/NAG/2025[2013-2014]Status: DisposedITAT Nagpur22 Sept 2025AY 2013-2014

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Pankaj Kumar

Section 143(3)Section 263Section 68

that the assessee was compelled in filing the appeal belatedly and we are satisfied that the delay in filing the appeal is due to reasonable cause. The assessee was actively pursuing the matter for appropriate legal remedy and he must not suffer for un–precedented latches. Liberal and proactive approach

Chundayil Kalam Girijadevi, Keralassery vs. ITO Ward 1 & Tps, Palakkad

ITA 564/COCH/2025[2018-19]Status: DisposedITAT Cochin22 Sept 2025AY 2018-19

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Padmnathan K.VFor Respondent: Smt. Leena Lal

Section 250Section 270ASection 271(1)(c)Section 4

rejected the appeal preferred by the Assessee holding that the Assessee had failed to bring on record any material to substantiate reasonable cause for not offering income of INR.10,00,000/- to tax and for claiming the higher exemption of INR.20,00,000/- (as opposed

Modern Automobiles Engineers, Chandigarh vs. Income Tax Officer, Ward 2(1), Chandigarh

ITA 383/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh22 Sept 2025AY 2017-18

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.382/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2017-18) & 2. आयकरअपीलसं./ Ita No.383/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2017-18) M/S Modern Automobiles Ito बनाम/ Engineers Ward No 2(1) 4 Mw, Ind Area Phase I Chandigarh-160017 Vs. Chandigarh-160002 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aahfm-3373-M (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Vineet Krishan (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Tarundeep Kaur (Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 03-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-09-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Twin Appeals By Assessee For Assessment Year (Ay) 2017-18 Assails Confirmation Of Quantum Addition As Well As Confirmation Of Penalty U/S 272A(1)(D) By Learned First Appellate Authority. The Impugned Orders Have Been Passed By Learned

For Appellant: Sh. Vineet Krishan (Advocate) – Ld. ARFor Respondent: Smt. Tarundeep Kaur (CIT) – Ld. Sr. DR

Section 143(3)Section 272A(1)(d)

other partner capable of taking care of tax matters for the assessee. This being so, in our considered opinion, the assessee had reasonable cause for non-representation before lower authorities. On these facts, we admit both the appeals. The quantum appeal stands restored back to the file

Modern Automobiles Engineers, Chandigarh vs. Income Tax Officer, Ward 2(1), Chandigarh

ITA 382/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh22 Sept 2025AY 2017-18

For Appellant: Sh. Vineet Krishan (Advocate) – Ld. ARFor Respondent: Smt. Tarundeep Kaur (CIT) – Ld. Sr. DR

Section 143(3)Section 272A(1)(d)

Sukhminder Singh, Chandigarh vs. Income Tax Officer, Ward 2(1), Chandigarh

In the result, the order of the Ld

ITA 278/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh22 Sept 2025AY 2011-12

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri T.N. Singhla, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR (Virtual)

Section 143Section 143(3)Section 148Section 234ASection 250Section 271(1)(b)Section 271(1)(c)Section 271A

preferred an appeal before the Tribunal. 6. At the time of hearing before us, the Ld. AR submitted that the assessee was prevented by reasonable cause from making timely compliance before the NFAC, since the notices were not effectively attended due to circumstances beyond the 3 assessee’s control

Late Sh. Lakha Singh Through Legal Heir Hira Singh Dera Pyara Singh Barna Thanesar Kurukshetra, Kurukshetra vs. The Income Tax Officer Ward-1 Aaykar Bhawan, Near Community Hall Sector-5, Kurukshetra Haryana, Kurukshetra

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

ITA 1151/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh22 Sept 2025AY 2012-2013

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 148

notice u/s 148 or notice u/s 142(1) was ever served upon the appellant and, as such, the appellant was prevented by sufficient and reasonable cause and not appearing before Ld. Assessing Officer. 4. That the Ld. CIT(A) has failed to admit the additional evidence as furnished before

Awez Wahab Shaikh, Sillod vs. The ITO, Ward 1(1), Aurangabad

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

ITA 1131/PUN/2025[2017-2018]Status: DisposedITAT Pune22 Sept 2025AY 2017-2018

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Manoj Tripathi

Section 139Section 142(1)Section 144Section 250Section 69A

latest email and contact detail on ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 4 Awez Wahab Shaikh

Shankar Saybu Rakhewar, Pune vs. ITO Ward -2, Nanded

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

ITA 1031/PUN/2025[2017-18]Status: DisposedITAT Pune22 Sept 2025AY 2017-18

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Manoj Tripathi

Section 144Section 250Section 69A

email id and contact detail on ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is set aside and the effective grounds of appeal raised by the assessee are allowed for statistical purposes. 7. In the result

Manicam Narayanan, Chennai vs. ACIT, Ncc-20(1), Chennai

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

ITA 1975/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Mr. V. Balaji, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 139Section 139(1)Section 142(1)Section 144Section 148Section 69A

income tax portal. After considering the Affidavit filed by the assessee and also hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeals on or before the due date prescribed under the law and thus, in the interests of justice

Avinash Ashok Chavan, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 4531/MUM/2025[2011-12]Status: DisposedITAT Mumbai22 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain

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. Therefore matter is restored back to Ld. CIT(A) with a direction to the assessee

Avinash Ashok Chavan, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 4530/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Sept 2025AY 2012-13

Bench: Shri Sandeep Gosain

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. Therefore matter is restored back to Ld. CIT(A) with a direction to the assessee

Surya Kiran Health & Educational Trust, Mumbai vs. CIT(Exemptions), Mumbai

ITA 4469/MUM/2025[2024-25]Status: DisposedITAT Mumbai22 Sept 2025AY 2024-25

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 10Section 11Section 12Section 12ASection 80GSection 80G(5)(iii)Section 80G(5)(iv)

also refused to condone the delay stating that the assessee has not shown a reasonable cause for delay in filing the application. The CIT(A) further stated that the assessee has not filed any evidence of actual activity being carried on by the assessee. The assessee is in appeal before

Shri Satguru Sainath Charitable Trust, Mumbai vs. CIT(Exemption), Mumbai

ITA 4468/MUM/2025[2024-25]Status: DisposedITAT Mumbai22 Sept 2025AY 2024-25

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 10Section 11Section 12Section 12ASection 80GSection 80G(5)(iii)Section 80G(5)(iv)

said application was also rejected by the CIT(E) stating that the assessee has not shown a reasonable cause for delay in filing the application and the CIT(E) did not condone the delay. Further the CIT(E) also held that the assessee has not offered any comments on violation ... Accordingly we are unable to agree with the finding of the CIT(E) that the rejection of first application is not a reasonable cause for the delay in filing the second application and the delay is thus condoned. As already stated the CIT(E) did not examine the application

Manju Bherulal Jain, Mumbai vs. ITO - 2(1), Mumbai

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

ITA 4303/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Sept 2025AY 2012-13

Bench: Shri Sandeep Gosain

Section 10(38)Section 143(3)Section 148Section 250Section 253