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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

Sumit Jindal, New Delhi vs. DCIT, Central Circle-5, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 1064/DEL/2023[2018-19]Status: DisposedITAT Delhi10 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 132(4)Section 153A

imposed u/s 271B of the act deserves to be deleted being the delay was not intentional but the appellant was prevented by reasonable cause for filing of tax audit report within stipulated time limit. That the appellant craves leave to add, alter, delete & modify any of the ground of appeal ... audited within the stipulated period and therefore the provision for Section 271B were clearly applicable in this case. The appellant could not provide any reasonable cause of failure which had prohibited him to get his books of account audited within the stipulated time. Therefore in my considered opinion this

Santosh Kumar Soni, Ambikapur Sarguja vs. Income-Tax Officer Ward-3, Korba, Chhattisgarh

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

ITA 495/RPR/2025[2013-14]Status: DisposedITAT Raipur09 Sept 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.495/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Santosh Kumar Soni Gurudwara Ward No.32, Ambikapur, Sarguja- 497 001 Pan: Efnps1748F

For Appellant: NoneFor Respondent: Ms. Manisha Kinnu, CIT-DR
Section 250

Though the appellant has not furnished any submission in response to the notices issued, the appeal cannot be kept pending for indefinite period without reasonable cause. It is observed that the appellant is not interested in prosecuting the appeal filed by him. All grounds of appeal are adjudicated together

Ponipireddy Rajyalakshmi, Eluru vs. Income Tax Officer, Ward-1, Eluru

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

ITA 362/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2019-20

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 142(1)Section 147Section 148Section 69A

other hand, vehemently opposed to the submissions of the Ld. AR and submitted that the onus is on the assessee to give sufficient and reasonable cause for day-to-day delay caused while filing the appeal before the Ld. CIT(A). In the absence of the same

Moturu Chandra Sekhara Rao, Usa vs. The Income Tax Officer, Ward 2(1), Vijayawada

In the result, appeal of the assessee is allowed for statistical purposes as indicated herein above

ITA 474/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2015-16

Bench: The Tribunal. In Respect Of The Belated Filing Of The Appeal, The Assessee Filed A Petition For Condonation Of Delay Along With An Affidavit & The Relevant Contents Are Scanned & Pasted Herein Below:

Section 147Section 249(4)

appeal beyond the prescribed time limit with a delay of 47 days, we are of the considered view that there is a sufficient and reasonable cause that prevented the assessee in filing the appeal within the prescribed time limit. Therefore, we hereby condone the delay of 47 days and proceed ... assessee has admitted in Form 35 that there is a delay in filing the appeal, the assessee has not given any sufficient and reasonable cause for such delay. Thus, the Ld. CIT(A) dismissed the appeal of the assessee in limine. Aggrieved by the order

Meera, Jaaipur vs. ITO Ward 7(1), Jaaipur, Jaipur

ITA 590/JPR/2025[2010-11]Status: DisposedITAT Jaipur09 Sept 2025AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Ashok Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 147Section 234ASection 54B

assessee is prevented in filing the appeal in time and we are satisfied that the delay in filing the appeal is due to reasonable cause. Thus, the delay of 106 days in filing the appeal by the assessee is condoned in view of the decision of Hon'ble Supreme Court

Dubbi Gram Sewa Sahkari Samiti Ltd, Dausa vs. ITO WD, Dausa

In the result, the appeal of the assessee is allowed

ITA 1283/JPR/2024[2018-19]Status: DisposedITAT Jaipur09 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Anoop Bhatia, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR (V.C.)
Section 139Section 144Section 148Section 263Section 270ASection 271(1)(c)Section 80P

assessee is prevented in filing the appeal in time and we are satisfied that the delay in filing the appeal is due to reasonable cause. Thus, the delay of 251 days in filing the appeal by the assessee is condoned in view of the decision of Hon'ble Supreme Court

Ratnatray Foundation, Pune vs. CIT (Exemption), Pune

In the result, both the appeals filed by the appellant are allowed for statistical purposes

ITA 1628/PUN/2025[2026-27]Status: DisposedITAT Pune09 Sept 2025AY 2026-27

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Smt Deepa KhareFor Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

filing of the appeals. 3. After hearing both the sides and perusing the averments made in the affidavits, we are satisfied that due to ‘reasonable cause’ assessee failed to file the appeals within the stipulated time. We note that the assessee would not have gained from filing the appeals with

Ratnatray Foundation, Nashik vs. CIT (Exemption), Pune

In the result, both the appeals filed by the appellant are allowed for statistical purposes

ITA 1627/PUN/2025[2026-27]Status: DisposedITAT Pune09 Sept 2025AY 2026-27

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Smt Deepa KhareFor Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

filing of the appeals. 3. After hearing both the sides and perusing the averments made in the affidavits, we are satisfied that due to ‘reasonable cause’ assessee failed to file the appeals within the stipulated time. We note that the assessee would not have gained from filing the appeals with

Shree Khandiba De vs. TAN Trust, Punevs.CIT-Exemption, Pune

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

ITA 1218/PUN/2025[-]Status: HeardITAT Pune09 Sept 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)

filing of the appeal. 3. After hearing both the sides and perusing the averments made in the affidavit, we are satisfied that due to ‘reasonable cause’ appellant failed to file the appeal within the stipulated time. We note that the appellant would not have gained from 2 Shree Khandiba Devasthan

Mudialy Fishermens Co-Op Society Ltd., Kolkata vs. ACIT, Circle 10(1), Kolkata

ITA 759/KOL/2025[2017-2018]Status: DisposedITAT Kolkata09 Sept 2025AY 2017-2018

Bench: The Ld Cit(A). Ld D.R. Supported The Order Of Ld Cit(A).

For Appellant: Mudialy Fishermens Co.opFor Respondent: ACIT, Circle 10(1) Kolkata

cooperative society and under the control of West Bengal Government. The contention raised in the petition is found to be plausible and a reasonable cause. Hence, I condone the delay of 320 days and admit the appeal for adjudication. 4. At the outset, ld AR of the assessee submitted that

Amiya Shankar Ghar, Bankura vs. ITO, Ward 3(1), Bankura

In the result, appeal of the assessee stands allowed

ITA 1443/KOL/2025[2014-2015]Status: HeardITAT Kolkata09 Sept 2025AY 2014-2015

Bench: Shri & Rajesh Kumarassessment Year : 2014-2015 Amiya Shankar Ghar, Ward Vs. Income Tax Officer, Ward No.08, Dewan Bazar, No.3(1), Bankura, Po: Sonamukhi, Po: Sonamukhi, Kendudihi, Dist: Bankura. Dist: Bankura. Pan/Gir No.Acypg 7746 H (Appellant) .. ( Respondent) Assessee By : Shri D.K.Sen, Adv Revenue By : Shri Sankar Naskar, Sr Dr

For Appellant: Shri D.K.Sen, AdvFor Respondent: Shri Sankar Naskar, Sr DR
Section 142(1)Section 147Section 148Section 149(1)(b)Section 271(1)(c)

reply, ld DR opposed the condonation petition. 4. After considering the rival submissions and perusing the condonation petition, I am satisfied that there was reasonable cause in filing the appeal belatedly by the assessee. Therefore, I condone the delay of 277 days and admit the appeal for adjudication

Family Physicians Association, Bangalore vs. Income Tax Officer, (Exemption), Ward, Bangalore

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

ITA 946/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Sept 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2016-17 Family Physicians Association, Vs. Ito (Exemptions), #202-3 Mahesh Clinic, Ward, R T Street, B V K Iyengar Road Cross, Bangalore. Bangalore – 560 053, Karnataka. Pan :Aaatf 1083 G Appellant Respondent Assessee By : Shri. Nagesh, Ca Revenue By : Shri. Ganesh R Gale, Standing Counsel For Department. Date Of Hearing : 15.07.2025 Date Of Pronouncement : 09.09.2025

For Appellant: Shri. Nagesh, CAFor Respondent: Shri. Ganesh R Gale, Standing Counsel for Department
Section 11(2)Section 143(1)Section 249(3)

delay of 2658 days in filing the appeal which is not in accordance with section 249(3) of the Act and there is no reasonable cause and he dismissed the appeal of the assessee. 3. Aggrieved from the above Order, assessee filed appeal before the Tribunal. The learned Counsel submitted

Raymond Vishal, Bangalore vs. Income Tax Office, Ward-1(2)(3), Bangalore

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

ITA 792/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Sept 2025AY 2017-18

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

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department
Section 250Section 271A

assessee submitted that there was no deliberate inaction or mala fide intention in filing appeal late. The delay was due to sufficient and reasonable cause. Refusal to condone will cause irreparable loss and injustice, while no prejudice will be caused to the Revenue. Reliance is placed on the judgment

Income-Tax Officer-8(3)(1), Mumbai vs. Vibgyor Texotech Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 4705/MUM/2025[2009-10]Status: DisposedITAT Mumbai09 Sept 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Suchitra Raghunath Kamble ()

Section 143(3)Section 147Section 271(1)(c)Section 274Section 292B

Mumbai-400015. Whereas in the course of proceedings before me for the assessment year 2009-10 it appears to me that you: have without reasonable cause failed to furnish me return of income which you were required furnish by a notice given under section ... notice given under section 139(1) or by a notice given under sect 139(2)/148 of the Income tax Act, 1961, No. dated reasonable cause failed to furnish it within the time allowed and manner required by the said section 139(1) or by s notice. or have with

Srinivasa Rao Saripudi, Vijayawada vs. Income Tax Officer, Ward 2(4), Vijayawada

In the result, appeal filed by the assessee is dismissed

ITA 200/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam08 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanआ.अपी.सं /Ita No.200/Viz/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Srinivasa Rao Saripudi Vs. Income Tax Officer Vijayawada Ward-2 (4) Pan:Apvps1663K Vijayawada (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: N O N E राज" व "ारा/Revenue By:: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 08/09/2025 घोषणा की तारीख/Pronouncement: 08/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated 17/04/2025 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2017-18. 2. None Appeared On Behalf Of The Assessee When This Appeal Was Called For Hearing Despite Various Notices Issued To The Assessee & Adjournment Of Hearing Was Granted On The Request Of The Assessee, Vide Order Dated 21/07/2025. Even After Taking Adjournment Of Hearing On 21/07/2025, The Assessee Did Not Bother To Appear Before The Tribunal On The Subsequent Dates. Accordingly, The Bench Proposes To Hear & Dispose Of This Matter, Ex-Parte.

For Appellant: N O N EFor Respondent: : Dr. Aparna Villuri, Sr. AR

appeal of the assessee is not maintainable as there is an inordinate delay of 276 days and the assessee has failed to explain any reasonable cause for the delay in filing the appeal. It is pertinent to note that despite several opportunities and notices issued by this Tribunal, the assessee ... failed to explain the delay of 276 days in filing the present appeal. Thus, in the absence of the explanation of any reasonable cause of such a delay in filing the appeal, the appeal of the assessee is not maintainable and liable to be dismissed on this ground alone. Hence

Pushpa Upadhyay, Jaipur vs. Income Tax Officer, Ward-1(4), Jaipur

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

ITA 896/JPR/2025[2014-15]Status: DisposedITAT Jaipur08 Sept 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri S.R. Sharma,CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 271(1)(c)

WARD 1(4), JAIPUR and bad in law in as much as the appellant was not aware and was also prevented by reasonable cause about fixation of appeal. 2. That without prejudice to the ground No. (1) above on the facts and in the circumstances of the case

Anguri Devi Khandelwal (Radha Mohan Khandelwal (Legal Heir), Jaipur vs. DCIT Circle-4, Jaipur

In the result, the appeal of the assessee is allowed

ITA 390/JPR/2025[2018-2019]Status: DisposedITAT Jaipur08 Sept 2025AY 2018-2019

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ ITA No. 390/JPR/2025 निधर्धारणवर्ष / AssessmentYear : 2018-19 Smt.Anguri Devi Khandelwal Shri Radha Mohan Khandelwal (Legal Heir) 674, Khandaka Mansion, Bordi Ka Rasta Kishanpole Bazar, Jaipur – 302 001 बनाम Vs. The DCIT Circle-4 Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AIHPK 4203 A अपीलार्थी / Appellant निधर्धारिती की ओरसे / Assesseeby : Shri Rohan Sogani, CA राजस्व की ओरसे

For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 272A(1)Section 272A(1)(d)Section 273B

eventually ensured within the extended opportunity provided by the ld. AO. 4. Section 273B provides immunity from penalty under Section 272A(1)(d) if reasonable cause is demonstrated. The circumstances of the instant case squarely fall under Section 273B, as genuine difficulties were faced by the legal heir ... assessee’s death, fulfilling the condition of ‘reasonable cause’. 5. SUPPORTING CASE LAWS 5.1. Hon’ble Apex Court in Hindustan Steel Ltd. vs. State of Orissa (1973) 83 ITR 26 (SC) has observed that an order imposing penalty for failure to carry out a statutory obligation is the result

Ranjit Dharamsinhbhai Desai, Ahmedabad vs. The ITO, Ward-4(2)(3), Ahmedabad

In the result, the appeal of the assessee is, therefore, dismissed

ITA 468/AHD/2025[2018-19]Status: HeardITAT Ahmedabad08 Sept 2025AY 2018-19

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

For Appellant: Respondent byFor Respondent: Smt. Mamta Singh, Sr. DR
Section 250

present for the assessee. It seems that the assessee is not interested in pursuing the appeal. However, since the assessee has not adduced any reasonable cause for the delay in filing of appeal, the same is not condoned by us and the appeal, as a consequence, is dismissed

Pleasure Agro Private Limited (As A Successor - in Interest of Erstwhile Vishwaraja Properties and Consultancies Private Limited, Pune vs. DCIT Circle 8, Pune

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

ITA 944/PUN/2025[2015-16]Status: DisposedITAT Pune08 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Digambar SurwaseFor Respondent: Shri Shashank Ojha
Section 143(3)Section 250

condonation of delay. 3. After hearing both the sides and perusing the averments made in the condonation applications, we are satisfied that due to ‘reasonable cause’ assessee failed to file the appeals within the stipulated time. We note that the assessee has not gained from filing the appeals with ... assessee company with Pleasure Agro Private Limited. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned orders for both the assessment years are accordingly set aside. 8. In the result, both the appeals of the assessee are allowed for statistical

Pleasure Agro Private Limited (As A Successor - in Interest of Erstwhile Vishwaraja Properties and Consultancies Private Limited, Pune vs. DCIT Circle 8, Pune

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

ITA 943/PUN/2025[2014-15]Status: DisposedITAT Pune08 Sept 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Digambar SurwaseFor Respondent: Shri Shashank Ojha
Section 143(3)Section 250

condonation of delay. 3. After hearing both the sides and perusing the averments made in the condonation applications, we are satisfied that due to ‘reasonable cause’ assessee failed to file the appeals within the stipulated time. We note that the assessee has not gained from filing the appeals with ... assessee company with Pleasure Agro Private Limited. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned orders for both the assessment years are accordingly set aside. 8. In the result, both the appeals of the assessee are allowed for statistical