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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

Basavanneppa Guledakeri, Haveri vs. Income Tax Officer, Ward-2, Haveri

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

ITA 605/BANG/2025[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year :2017-18

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing
Section 115BSection 250Section 251Section 253(5)Section 69A

assessee for not presenting the appeal within the prescribed time. The explanation therefore, becomes relevant to determine whether the same reflect sufficient and reasonable cause on the part of the assessee in not filing these appeals within the prescribed time. 6.1 While considering a similar issue the Apex Court ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for not filing the appeal. We have to see the cause for the delay. When there was a reasonable cause, the period of delay

Settikere Shankarappa Murugeshaih, Tumkur vs. Income Tax Officer, Ward-1, Tumakuru

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

ITA 521/BANG/2025[2016-17]Status: DisposedITAT Bangalore15 Sept 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri Tarun Kumar M.K., A.RFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing
Section 250Section 253(5)

assessee for not presenting the appeals within the prescribed time. The explanation therefore, becomes relevant to determine whether the same reflect sufficient and reasonable cause on the part of the assessee in not filing this appeal within the prescribed time. We have gone through the reasons explained by the assessee ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for not filing the appeal. We have to see the cause for the delay. When there was a reasonable cause, the period of delay

Sha Pratapchand Pukharaj and Company, Vijayapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

In the result, the appeal of the assessee is allowed

ITA 2547/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R
Section 253Section 253(5)Section 263

assessee for not presenting the appeal within the prescribed time. The explanation, therefore, becomes relevant to determine whether the same reflects sufficient and reasonable cause on the part of the assessee in not filing the Sha Pratapchand Pukhraj and Company, Vijayapur Page 8 of 19 appeals within the prescribed time

Vanigota Sugar Trading Company, Vijapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

In the result, the appeal of the assessee is allowed

ITA 2545/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R
Section 253(5)Section 263

prescribed time. The explanation therefore, becomes relevant to determine whether the same reflect Vanigota Sugar Trading Company, Vijaypur Page 7 of 19 sufficient and reasonable cause on the part of the assessee in not filing these appeals within the prescribed time. 4.1 While considering a similar issue the Apex Court ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for not filing the appeal. We have to see the cause for the delay. When there was a reasonable cause, the period of delay

Suraj Somaru Varma, Bhiwandi vs. Itba, Kalyan

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

ITA 1776/MUM/2025[2017-18]Status: DisposedITAT Mumbai15 Sept 2025AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)

Section 250Section 69A

Registry. In this regard, we have heard both the parties and perused the affidavit placed on record and we find that there was reasonable cause for the delay in filing the present appeal by the assessee due to lack of diligence on the part of Counsel who was appointed

Pradeep Biharising Bundele, Jalna vs. ITO Ward-1, Jalna

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

ITA 754/PUN/2025[2012-2013]Status: DisposedITAT Pune12 Sept 2025AY 2012-2013

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Harshit Kabra (Virtual)For Respondent: Shri Shashank Ojha
Section 144Section 147Section 148Section 151Section 153CSection 234ASection 250Section 69

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. Impugned order is set aside and all the grounds raised in the instant appeal are allowed for statistical purposes. 8. In the result, appeal

Mr. Vijay Bajirao Balwadkar, Pune vs. ITO, Ward 2(2) Pune, Pune

In the result, appeal of the assessee is allowed as per terms indicated above

ITA 1637/PUN/2025[2015-16]Status: DisposedITAT Pune12 Sept 2025AY 2015-16

Bench: Dr.Manish Borad

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Sanjay Dhivare
Section 14Section 147Section 148Section 151Section 250Section 56(2)(viib)

Vijay Bajirao Balwadkar 3. After hearing both the sides and perusing the averments made in the condonation application, I am satisfied that due to ‘reasonable cause’ appellant failed to file the appeal within the stipulated time. I note that the appellant would not have gained from filing the appeal with

Shivprasad Kashinath Desai, Sindhudurg vs. ITO Ward, Kudal

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

ITA 1003/PUN/2025[2016-17]Status: DisposedITAT Pune12 Sept 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Prayag JhaFor Respondent: Shri Shashank Ojha
Section 250Section 271(1)(b)Section 273B

have gone through the averments made by ld. Counsel for the assessee and considering the practical difficulties faced by the assessee and the ‘reasonable cause’ which prevented him from appearing before ld. AO, we find that assessee deserves immunity from levy of impugned penalty in light of the provisions ... section 273B of the Act as the assessee has proved that there was ‘reasonable cause’ for the said failure in attending to the notice of hearing sent by ld. AO. We therefore delete the impugned penalty of Rs.10,000/- levied u/s.271(1)(b) of the Act. Finding of ld.CIT

Dy. Commissioner of Income Tax, Circle-8, Pune vs. Shri Aslam Badshah Shaikh, Pune

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

ITA 2355/PUN/2024[2017-18]Status: DisposedITAT Pune12 Sept 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 144Section 250Section 69A

cash deposit during the denovo assessment proceedings. Respondent-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 Revenue are allowed for statistical purposes. 6. In the result

Nimmatoori Ramesh Babu, Hyderabad vs. ACIT., Central Circle 2(4), Hyderabad

In the result, appeal ITA

ITA 597/HYD/2025[2017-18]Status: DisposedITAT Hyderabad12 Sept 2025AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Sood

For Respondent: Sri Posu Babu Alli, Sr. AR
Section 143(3)Section 269Section 271Section 271DSection 271D(2)Section 273BSection 4

ITA.Nos.594, 596 & 597 /Hyd./2025 10. Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that there is a reasonable cause as referred to in section 273B of the Act for the acceptance of the impugned cash by the assessee and that therefore, the penalty ... sale of agricultural land was not covered u/sec.269SS of the Act. Under those facts, the Tribunal came to the conclusion that, there is a reasonable cause for the assessee for accepting cash for sale of agricultural land and thus, directed the Assessing Officer to delete the penalty. In the present

Late Nimmatoori Rajababu L/R by Anudeep Nimmatoori, Hyderabad vs. ACIT., Central Circle 2(4), Hyderabad

In the result, appeal ITA

ITA 596/HYD/2025[2017-18]Status: DisposedITAT Hyderabad12 Sept 2025AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Sood

For Respondent: Sri Posu Babu Alli, Sr. AR
Section 143(3)Section 269Section 271Section 271DSection 271D(2)Section 273BSection 4

ITA.Nos.594, 596 & 597 /Hyd./2025 10. Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that there is a reasonable cause as referred to in section 273B of the Act for the acceptance of the impugned cash by the assessee and that therefore, the penalty ... sale of agricultural land was not covered u/sec.269SS of the Act. Under those facts, the Tribunal came to the conclusion that, there is a reasonable cause for the assessee for accepting cash for sale of agricultural land and thus, directed the Assessing Officer to delete the penalty. In the present

Late Nimmatoori Raja Babu, Hyderabad vs. ACIT., Central Circle 2(4), Hyderabad

ITA 594/HYD/2025[2016-17]Status: DisposedITAT Hyderabad12 Sept 2025AY 2016-17

Bench: Shri Manjunatha G & Shri Ravish Sood

For Respondent: Sri Posu Babu Alli, Sr. AR
Section 143(3)Section 269Section 271Section 271DSection 271D(2)Section 273B

regard to the impugned double taxation. 10. Without prejudice to other grounds, the Ld. CIT(A) ought to have appreciated that there is a reasonable cause as referred to in section 273B of the Act for the acceptance of the impugned cash by the assessee and that therefore, the penalty ... sale of agricultural land was not covered u/sec.269SS of the Act. Under those facts, the Tribunal came to the conclusion that, there is a reasonable cause for the assessee for accepting cash for sale of agricultural land and thus, directed the Assessing Officer to delete the penalty. In the present

Rain Cements, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 540/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Sept 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Deepak Chopra, AdvocateFor Respondent: Sri Madan Mohan Meena, Sr. AR
Section 115Section 115JSection 143(1)Section 234CSection 246A

laws to come to the conclusion that delay was mala fide. 6. That the CIT(A) erred in ignoring that since the Appellant demonstrated reasonable cause for belated filing of appeal, this was a fit case for the CIT(A) to exercise affirmative discretion in condoning delay. 7. That ... delay in filing of the appeal before the learned CIT(A), is not convincing and 6 ITA.No.540/Hyd./2025 does not come under ‘reasonable cause’ for condoning the huge delay of 1491 days. Therefore, the learned CIT(A) rejected the explanation for delay in filing of the appeal and dismissed

Agras Residency Private Limited, Hyderabad vs. DCIT, Circle-1(1), Hyderabad

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

ITA 1159/HYD/2025[2013-14]Status: DisposedITAT Hyderabad12 Sept 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Vinod, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR
Section 147Section 148Section 68

bona fide. In the absence of any contrary material brought by the Revenue, we are of the view that the assessee was prevented by reasonable cause from filing the appeal within the prescribed time. Accordingly, taking a liberal approach, we condone the delay of 45 days in filing

Nurul Islam Mullick, Howrah vs. ITO, Ward 61(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 799/KOL/2025[2017-18]Status: DisposedITAT Kolkata12 Sept 2025AY 2017-18

Bench: Shri Rajesh Kumarassessment Year : 2017-18 Nurul Islam Mullick, Bhupatipur, Vs. Income Tax Officer, Ward 61 Munshirhat, Jagatballavpur, (1), Kolkata Howrah-711410 Pan/Gir No. Adkpm 8272 F (Appellant) .. ( Respondent) Assessee By : Shri Miraz D. Shah, Ar Revenue By : Shri Shankar Naskar, Sr. Dr Date Of Hearing : 11/09/2025 Date Of Pronouncement : 12/09/2025 O R D E R

For Appellant: Shri Miraz D. Shah, ARFor Respondent: Shri Shankar Naskar, Sr. DR
Section 143(3)

this backdrop that there was delay of 412 days. It is also stated that the delay in filing the appeal was due to reasonable cause and requested to condone the delay. After considering the condonation petition and hearing the parties, I am satisfied that there was reasonable cause in filing

Ratan Shaw, Naihati vs. ITO, Ward 51(3), Kolkata

The appeal of the assessee is allowed

ITA 309/KOL/2025[2015-16]Status: DisposedITAT Kolkata12 Sept 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.309/Kol/2025 Assessment Year: 2015-16 Ratan Shaw………………….…………………....…………………....Appellant 15, L. N. Kabiraj Road, Gorifa, Naihati, Wb-743166. [Pan: Bvups8926H] Vs. Ito, Ward-51(3), Kolkata..……………....…..………………….…..... Respondent Appearances By: Shri Anil Kochar, Adv., Appeared On Behalf Of The Appellant. Shri Abhijit Adhikari, Jcit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 21, 2025 Date Of Pronouncing The Order : September 12, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (A), Chennai (Hereinafter Referred To As “Ld. Cit(A)”) Dated 22.11.2024 Passed Under Section 250 Of The Income- Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. At The Outset, It Is Noted That There Is A Delay Of 12 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 143(3)Section 250Section 69

filed a condonation petition explaining the reasons or such delay. After considering the submissions and materials on record, we are satisfied that there was reasonable cause for the delay in filing the appeal. Accordingly, the said delay is condoned, and the appeal is admitted for adjudication. I.T.A. No.309/Kol/2025 Ratan Shaw

Chaktentul Skus Ltd., Durgapur vs. ITO, Ward 1(1), Durgapur

ITA 1464/KOL/2025[2018-2019]Status: DisposedITAT Kolkata12 Sept 2025AY 2018-2019

Bench: 28-02-2024 & In The Process There Is Delay Of 403 Days In Filing The Instant Appeal. The Main Reason Is The Appellant Was Suffering From Prolonged Illness & Was Under Medical Supervision. The Appellant Is Attaching A Copy Of Medical Certificate Issued By The Doctor In This Respect. 2. That The Limitation Period Prescribed In Income Tax Act, 1961 For Filing The Appeal Before This Appellate Tribunal Against The Order Of The Income Tax Officer Is 60 Days From The Date Of The Receipt Of The Impugned Order.

Section 250Section 270ASection 271ASection 272A(1)(d)Section 69A

commission/brokerage with evidences on demand of Assessing officer. 4. That passing of 'BEST JUDGEMENT ASSESSMENT order is bad in law as there has been reasonable cause for non-compliance of notice by the appellant. 5. That appellant has all the relevant documents to prove the source of cash deposit

Palanisamy Anand, Salem vs. ITO, Ward-1(6), Salem

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

ITA 1528/CHNY/2025[2017-18]Status: DisposedITAT Chennai12 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1528/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2017-18 Palanisamy Anand, Income Tax Officer, D.No.2, Mariamman Kovil Street, Vs. Ward -1(6), Seshanchavadi, Valappadi Salem. Salem– 636 111. [Pan:Amcpa-1644-C] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. S. Sridhar, Advocate. प्रत्यथी की ओर से/Respondent By : Shri. Arv Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 12.09.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. ARV Sreenivasan, CIT
Section 144Section 147Section 69

After considering the Affidavit filed by the assessee and also hearing :-2-: ITA. No:1528/Chny/2025 both the parties, we find that there is a reasonable cause for the assessee in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice

Asklepios Remedies Pvt. Ltd, Patna vs. NFAC, Delhi

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

ITA 202/PAT/2025[2018-19]Status: DisposedITAT Patna11 Sept 2025AY 2018-19

Bench: Shri George Mathan

Section 143(3)Section 37

/mobile number of the appellant. 3. For that the Ld. CIT(A) has failed to appreciate that the appellant was prevented by sufficient and reasonable cause for not making compliance to the notices as no information of its uploading were received on registered e- mail / mobile number of the appellant

Netink Technologies Private Limited, Bhopal vs. DCIT/ACIT 3(1), Bhopal

In the result the “impugned order” is set aside as and by

ITA 155/IND/2025[2018-19]Status: DisposedITAT Indore11 Sept 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M Joshinetink Technologies Dcit/Acit 3(1), बनाम/ Private Limited, Bhopal Vs. Plot No.6, Behind Congress Bhawan, Shivaji Nagar, Bhopal (Pan:Aaecn4127C) (Assessee/Appellant) (Revenue/Respondent) Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Dr Date Of Hearing 02.09.2025 Date Of Pronouncement 11.09.2025 आदेश / O R D E R

Section 144Section 246ASection 249(3)Section 250Section 253

days without any evidence in support could not be condoned. 5.1.6 Further, the language used in section 249(3) is sufficient cause" and not "reasonable cause". 'Sufficient cause' is much more stringent that the term 'reasonable cause' and even if a cause is reasonable, it has to be ascertained whether