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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

Damodharan Vinodh Kumar, Tiruvallur vs. ITO, Ncw-7(3), Chennai

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

ITA 3795/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Feb 2026AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3795/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Damodharan Vinodh Kumar, Vs. The Income Tax Officer, Flat No. 312, Bougainvillea Flora Non Corporate Ward 7(3), Apartments, Pattabi, Pattabiram, Chennai. Tiruvallur 600 072. [Pan:Ahcpv6672N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Hitesh, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 17.02.2026 घोषणा की तारीख /Date Of Pronouncement : 25.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 07.11.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. At The Outset, The Ld. Ar Shri Hitesh, Advocate Submits That The Ld. Cit(A) Dismissed The Appeal Without Condoning The Delay In Filing The Appeal For Ay 2020-21. He Prayed To Remand The Matter To The File Of The 2

For Appellant: Shri Hitesh, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

proper guidance, he could not effectively track the electronic notices served through the income tax portal and email. We find that there is reasonable cause for the delay involved in filing of the appeal. Accordingly, taking into the consideration of the submissions

Mysore Dasaprakash, Chennai vs. ITO, Ncc-7(1), Chennai

The appeal of the assessee is allowed for statistical purposes

ITA 3651/CHNY/2025[2019-20]Status: DisposedITAT Chennai25 Feb 2026AY 2019-20

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3651/Chny/2025 िनधा%रण वष% /Assessment Year: 2019-20

For Appellant: Mr. Hitesh, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 148Section 148ASection 250

managing partner. Considering the facts and circumstances unique to the assessee's case, we are of the considered view that there is a reasonable cause for the delay in filing the appeal before the CIT(A). We therefore condone the delay in filing the appeal before the CIT(A). Further

Angamuthu Veeraraghavan, Trichy vs. ITO, Ward-2(1), Trichy

The appeal of the assessee is allowed for statistical purposes

ITA 3618/CHNY/2025[2016-17]Status: DisposedITAT Chennai25 Feb 2026AY 2016-17

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No. 3618/Chny/2025 िनधा$रण वष$ /Assessment Year: 2016-17

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 147Section 148Section 148ASection 250Section 69ASection 69C

more opportunity. Considering the facts and circumstances unique to the assessee's case we are of the considered view that there is a reasonable cause for the delay in filing the appeal before the CIT(A). We therefore remit the appeal back to the CIT(A) with the direction

Jagannathan Krishnaveni, Thanjavur vs. ITO, Ward-1, Kumbakonam

The appeal of the assessee is allowed for statistical purposes

ITA 3617/CHNY/2025[2019-20]Status: DisposedITAT Chennai25 Feb 2026AY 2019-20

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No. 3617/Chny/2025 िनधा$रण वष$ /Assessment Year: 2019-20

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 250Section 69B

counsel with regard to income tax matters who did not handle assessee's case properly. Accordingly the Ld. AR submitted that there is a reasonable cause for the delay in filing the appeal before the CIT(A). Considering the facts and circumstances unique to the assessee's case ... considered view that there is a reasonable cause for the delay in filing the appeal before the CIT(A). We therefore remit Jagannathan Krishnaveni :- 3 -: the appeal back to the CIT(A) with the direction to condone the delay and consider the appeal on merits as well as the legal

Dinesh Verma, Manali, Himachal Pradesh vs. ITO, ITO Ward Kullu

In the result, appeal filed by the Assessee is dismissed

ITA 897/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Vinamar Gupta, C.A (Virtually)For Respondent: Shri Manav Bansal, CIT, DR
Section 147Section 148Section 151ASection 263Section 270A

Having considered the explanation and keeping in view that substantial justice should prevail over technicalities, we are satisfied that the assessee was prevented by reasonable cause in filing the appeal within time. Accordingly, the delay of 40 days is condoned, and the appeal is admitted for adjudication on the merits

G2K Trust, Trichy vs. ITO, Ward-2(1), Trichy

In the result, both the appeals filed by the assessee are dismissed

ITA 3114/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Feb 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.3113 & 3114/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 & 2018-19 G2K Trust, Vs. The Income Tax Officer, No. 5, Abila Avenue, Santosh Garden, Ward 2(1), Kulumani Main Road, Woraiyur, Tiruchirappalli. Trichy 620 102. [Pan: Aactg4763G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. K. Abhirame, Advocate ""थ" की ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.02.2026 घोषणा की तारीख /Date Of Pronouncement : 24.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 04.07.2025 & 15.07.2025 Passed By The Addl/Jcit(A), Panaji For The Assessment Years 2017-18 & 2018-19 Respectively.

For Appellant: Ms. K. Abhirame, AdvocateFor Respondent: Ms. T. Mythili, JCIT
Section 143(1)

Online ITAT 12 at page 7 of the paper book and argued that the death of the auditor constitute reasonable cause. Further, she referred to the decision of the Hon’ble High Court of Bombay in the case of Al Jamia Mohammediyah Education Society ... months. She vehemently argued that the mere reason of assessee’s auditor, who expired six month before cannot be a valid or reasonable cause for the delay of 2235 days in filing the appeal and prayed that the reasons stated by the assessee should be rejected and dismiss the appeal

G2K Trust, Trichy vs. ITO, Ward-2(1), Trichy

In the result, both the appeals filed by the assessee are dismissed

ITA 3113/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Feb 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.3113 & 3114/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 & 2018-19 G2K Trust, Vs. The Income Tax Officer, No. 5, Abila Avenue, Santosh Garden, Ward 2(1), Kulumani Main Road, Woraiyur, Tiruchirappalli. Trichy 620 102. [Pan: Aactg4763G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. K. Abhirame, Advocate ""थ" की ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.02.2026 घोषणा की तारीख /Date Of Pronouncement : 24.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 04.07.2025 & 15.07.2025 Passed By The Addl/Jcit(A), Panaji For The Assessment Years 2017-18 & 2018-19 Respectively.

For Appellant: Ms. K. Abhirame, AdvocateFor Respondent: Ms. T. Mythili, JCIT
Section 143(1)

Online ITAT 12 at page 7 of the paper book and argued that the death of the auditor constitute reasonable cause. Further, she referred to the decision of the Hon’ble High Court of Bombay in the case of Al Jamia Mohammediyah Education Society ... months. She vehemently argued that the mere reason of assessee’s auditor, who expired six month before cannot be a valid or reasonable cause for the delay of 2235 days in filing the appeal and prayed that the reasons stated by the assessee should be rejected and dismiss the appeal

Basaveshwer Devalay English Medium Higher Primary School, Bijapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

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

ITA 2047/BANG/2025[2016-17]Status: DisposedITAT Bangalore24 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: NoneFor Respondent: Smt. N. Hemalatha, CIT-DR
Section 10Section 139(1)Section 142(1)Section 143(2)Section 148Section 148ASection 271Section 271(1)(b)Section 271FSection 273B

failed to appreciate the fact that penalty imposed u/s 271 F was not automatic and was subject to consideration u/s 273B, as there was reasonable cause for non-filIng of Return of Income. 4. That the Learned Commnr. failed to appreciate that Assessing Officer in original Assessment has allowed exemption

Khaja Education Society, Kalaburgi vs. Commissioner of Income Tax (Exemptions), Bangalore

In the result the appeals are allowed for statistical purposes

ITA 1608/BANG/2025[NA ]Status: DisposedITAT Bangalore24 Feb 2026

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Section 12Section 80

registration certificate was found to have been granted to the assessee by CIT Exemption as religious trust. We find that there is a reasonable cause that on coming to know about the consequences of the registration certificate granted to the assessee, the assessee immediately filed an appeal. Thus, delay

Khaja Education Society, Kalaburgi vs. Commissioner of Income Tax (Exemptions), Bangalore

In the result the appeals are allowed for statistical purposes

ITA 1607/BANG/2025[NA]Status: DisposedITAT Bangalore24 Feb 2026

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Section 12Section 80

registration certificate was found to have been granted to the assessee by CIT Exemption as religious trust. We find that there is a reasonable cause that on coming to know about the consequences of the registration certificate granted to the assessee, the assessee immediately filed an appeal. Thus, delay

Mohammad Umar Abdul Hasan Khan (Through Legal Heir Wife Haseena Bano), Boiser vs. Ward 1, Palghar

ITA 8815/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Feb 2026AY 2020-21

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Kirit ShethFor Respondent: Shri Bhagirath Ramawat
Section 144Section 144BSection 147Section 148Section 148ASection 159

consultant. In our view, the delay in filing the appeal was inadvertent and bonafide. Accordingly, we hold that the Assessee was prevented by reasonable cause from filing the appeal within the prescribed time. Therefore, we condone the delay of 18 days in filing the present appeal and proceed to adjudicate

Shabana Kaizer Jangbarwala, Mumbai vs. ITO Ward-42(3)(3), Mumbai

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

ITA 8636/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Feb 2026AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

Section 147Section 249(2)Section 250Section 69C

specifically due to non-receipt of the assessment order, thus the learned CIT(A) failed to appreciate that the appellant had demonstrated sufficient and reasonable cause for the delay, which was neither found to be false, misleading, intentional nor deliberate. 3. The refusal to condone the delay and dismissal

M/S Mumbadevi Veyhicles, Mumbai vs. ITO Ward 41(4)(2), Mumbai

In the result the appeal of the assessee is allowed

ITA 7899/MUM/2025[2014-15]Status: DisposedITAT Mumbai24 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 151Section 250Section 271(1)(c)

that even where the return was filed only in response to notice under section 148, penalty would not automatically follow if there existed a reasonable cause. 18. The learned Departmental Representative (DR), on the other hand, strongly supported the orders of the lower authorities. It was submitted that the assessee ... assessee that the return was not filed due to an inadvertent mistake on the part of the accountant cannot constitute a valid or reasonable cause in the eyes of law. According to the learned DR, statutory compliance is the responsibility of the assessee, and negligence or oversight of an accountant

Naushad Ali Abdul Haq Shaik, Mumbai vs. Income Tax Officer 42(2)(4), Mumbai

ITA 7339/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Akshay JainFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 245

assessee is prevented by a reasonable Act unless the assessee is prevented by a reasonable Act unless the assessee is prevented by a reasonable cause from filing the appeal in time. cause from filing the appeal in time. 5.2 The appellant ought to have filed the appeal within ... tendered by the assessee constitutes a view, the explanation tendered by the assessee constitutes a view, the explanation tendered by the assessee constitutes a "reasonable cause." The delay was neither deliberate nor a result of "reasonable cause." The delay was neither deliberate nor a result of "reasonable cause." The delay

Naushad Ali Abdul Haq Shaikh, Mumbai vs. Income Tax Officer 42(2)(4), Mumbai

ITA 7338/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Akshay JainFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 245

assessee is prevented by a reasonable Act unless the assessee is prevented by a reasonable Act unless the assessee is prevented by a reasonable cause from filing the appeal in time. cause from filing the appeal in time. 5.2 The appellant ought to have filed the appeal within ... tendered by the assessee constitutes a view, the explanation tendered by the assessee constitutes a view, the explanation tendered by the assessee constitutes a "reasonable cause." The delay was neither deliberate nor a result of "reasonable cause." The delay was neither deliberate nor a result of "reasonable cause." The delay

Anand Kumar Jain, Agra vs. Income Tax Officer, Ward-1(1)(1), Agra

In the result, appeal filed by the assessee is allowed

ITA 345/AGR/2025[2017-2018]Status: DisposedITAT Agra20 Feb 2026AY 2017-2018

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18 Anand Kumar Jain Vs. Income-Tax Officer, 30/41, Chhipitola Ward-1 (1)(1), Agra Agra Pan :Aarpj3189L (Appellant) (Respondent) Assessee By Shri Gaurav Goyal , Ca Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 20.02.2026 Order

Section 115BSection 143(2)Section 44ASection 68

peculiar facts in this case, I am of the view that the assessee was ill informed of the status of the appeals. There is reasonable cause for such huge delay. To meet the ends of justice, I proceed to admit the appeal for adjudication and accordingly, the delay is condoned

Pavithra Rangasamy, France vs. The Income Tax Officer, International Taxation, Ward 2(1), Chennai

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

ITA 4083/CHNY/2025[2016-17]Status: DisposedITAT Chennai20 Feb 2026AY 2016-17

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita Nos.: 4081, 4082 & 4083/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Ms. Pavithra Rangasamy, The Income Tax Officer, 65, Avenue Puvis De Chavannes, Vs. International Taxation Ward 92400 Courbevoie, 2(1), France Chennai. Pan: Antpp 7045G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई क" तारीख/Date Of Hearing : 18.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.02.2026

For Appellant: Shri Shrenik Chordia, CAFor Respondent: Ms. V. Aswathy, JCIT
Section 147Section 250Section 271(1)(c)

delay of 502 days in filing the appeal against the quantum appeal and there is no reasonable cause for condoning the same. Further, we also notice that the assessment has been completed on best judgment assessment u/s. 147 r.w.s. 144 r.w.s.144B of the Act. 3. On perusing the orders ... before the FAA, which has resulted in delay. However, the FAA rejected the assessee’s request for condonation by holding that there is no reasonable cause and dismissed the appeals of the assessee. In our view, the reason cited by assessee before FAA for belated filing of appeals are bonafide

Pavithra Rangasamy, France vs. The Income Tax Officer, International Taxation, Ward 2(1), Chennai

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

ITA 4082/CHNY/2025[2016-17]Status: DisposedITAT Chennai20 Feb 2026AY 2016-17

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita Nos.: 4081, 4082 & 4083/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Ms. Pavithra Rangasamy, The Income Tax Officer, 65, Avenue Puvis De Chavannes, Vs. International Taxation Ward 92400 Courbevoie, 2(1), France Chennai. Pan: Antpp 7045G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई क" तारीख/Date Of Hearing : 18.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.02.2026

For Appellant: Shri Shrenik Chordia, CAFor Respondent: Ms. V. Aswathy, JCIT
Section 147Section 250Section 271(1)(c)

delay of 502 days in filing the appeal against the quantum appeal and there is no reasonable cause for condoning the same. Further, we also notice that the assessment has been completed on best judgment assessment u/s. 147 r.w.s. 144 r.w.s.144B of the Act. 3. On perusing the orders ... before the FAA, which has resulted in delay. However, the FAA rejected the assessee’s request for condonation by holding that there is no reasonable cause and dismissed the appeals of the assessee. In our view, the reason cited by assessee before FAA for belated filing of appeals are bonafide

Pavithra Rangasamy, France vs. The Income Tax Officer, International Taxation, Ward 2(1), Chennai

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

ITA 4081/CHNY/2025[2016-17]Status: DisposedITAT Chennai20 Feb 2026AY 2016-17

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita Nos.: 4081, 4082 & 4083/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Ms. Pavithra Rangasamy, The Income Tax Officer, 65, Avenue Puvis De Chavannes, Vs. International Taxation Ward 92400 Courbevoie, 2(1), France Chennai. Pan: Antpp 7045G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई क" तारीख/Date Of Hearing : 18.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.02.2026

For Appellant: Shri Shrenik Chordia, CAFor Respondent: Ms. V. Aswathy, JCIT
Section 147Section 250Section 271(1)(c)

delay of 502 days in filing the appeal against the quantum appeal and there is no reasonable cause for condoning the same. Further, we also notice that the assessment has been completed on best judgment assessment u/s. 147 r.w.s. 144 r.w.s.144B of the Act. 3. On perusing the orders ... before the FAA, which has resulted in delay. However, the FAA rejected the assessee’s request for condonation by holding that there is no reasonable cause and dismissed the appeals of the assessee. In our view, the reason cited by assessee before FAA for belated filing of appeals are bonafide

The Uppilipalayam Mill Industrial Workers Coop House Construction Society Ltd., Coimbatore vs. The Income Tax Officer, Non Corporate Ward 1(4), Coimbatore

In the result, both the captioned appeals filed by the assessee are allowed for statistical

ITA 3898/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Feb 2026AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giriआयकर अपील सं./Ita No 3897 &3898 /Chny/2025 "नधा"रण वष"/Assessment Year: 2020-21 & 2020-21 The Uppilipalayam Mill Industrial V. Ito, Workers Coop House Construction Non Corporate Ward Society Ltd., 1(4) Coimbatore Uppilipalayam Post, Coimbatore-641015 [Pan: Awvpg 3572 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Ms. A Vijayalakshmi, CAFor Respondent: 17.02.2026
Section 142(1)Section 143(2)Section 270ASection 80P(2)(a)

Const So Ltd Vs ITO NCWQ 1(4) Coimbatore :: 3 :: without appreciating the delay that was neither deliberate nor intentional and was supported by reasonable cause. 4. At the outset, we note that the Ld.CIT (A) has dismissed the appeal in limine on account of delay