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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

The Kattoor Service Cooperative Bank Limited, Thrissur vs. Income Tax Officer, Ward 2(1), Thrissur

In the result, the appeals filed by the assessee stand dismissed

ITA 560/COCH/2025[2015-16]Status: DisposedITAT Cochin26 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69ASection 80P

condonation of delay, in the absence of any evidence contrary, we are of the considered opinion that the appellant society is prevented by sufficient reasonable cause in filing the appeal within the prescribed limit. Accordingly, we condone the delay and admit the appeal for adjudication. 8. The learned counsel

The Kattoor Service Cooperative Bank Limited, Thrissur vs. Income Tax Officer, Ward 2(1), Thrissur

In the result, the appeals filed by the assessee stand dismissed

ITA 559/COCH/2025[2014-15]Status: DisposedITAT Cochin26 Aug 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69ASection 80P

condonation of delay, in the absence of any evidence contrary, we are of the considered opinion that the appellant society is prevented by sufficient reasonable cause in filing the appeal within the prescribed limit. Accordingly, we condone the delay and admit the appeal for adjudication. 8. The learned counsel

Sai Motors, Indore (M.P.) vs. The Income-Tax Officer, Khargone

In the result appeal of the assessee is partly allowed for

ITA 177/IND/2025[2017-18]Status: DisposedITAT Indore26 Aug 2025AY 2017-18

Bench: Shri Manish Boradsai Motors, Income Tax Officer, C/O Sv Agrawal & Associates, Khargone 25, Joy Builders Colony, Near Rafeal Tower, Vs. Old Palasia, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Acyfs6381E Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 25.08.2025 Date Of Pronouncement 26.08.2025 O R D E R

Section 115BSection 131Section 133(6)Section 143(1)Section 144Section 249(3)Section 44ASection 69A

should be provided reasonable opportunity of being heard. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. The effective grounds raised in this appeal are allowed for statistical purpose. 8. In the result appeal of the assessee is partly allowed

Dharmendra Kumar, Khandwa vs. ITO, Khandwa

Appeal is allowed for statistical purpose

ITA 521/IND/2023[2018-19]Status: DisposedITAT Indore26 Aug 2025AY 2018-19

Bench: Shri B.M. Biyani

Section 115BSection 143(2)Section 144Section 147Section 148Section 148ASection 44A

521/Ind/2023 - AY 2018-19 10. On the facts and circumstances of the case and applicable law, Ld. CIT(A) erred in not considering the reasonable cause for delay in filing of appeal being the medical issues of the assessee. 11.On the facts and circumstances of the case and applicable

Anju Singh, Hardoi vs. ITO-3(2), Hardoi

In the result, the appeal of the assessee stands allowed

ITA 65/LKW/2025[2019-20]Status: DisposedITAT Lucknow26 Aug 2025AY 2019-20

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 142(1)Section 144Section 147Section 148Section 69A

assessee. Further, the Assessing Officer has failed to establish that the failure of the assessee to appear for hearing during assessment proceedings was without reasonable cause. The I.T.A. No.65/Lkw/2025 Assessment Year:2019-20 3 Assessing Officer has passed a hasty order without providing reasonable opportunity to the assessee and without

Vikram Narendra Patil, Aurangabad vs. ITO Ward - 1(2), Aurangabad

In the result, the appeal filed by the assesee is partly allowed

ITA 950/PUN/2025[2017-18]Status: DisposedITAT Pune26 Aug 2025AY 2017-18

Bench: Dr.Manish Borad

For Appellant: Shri Prayag JhaFor Respondent: Shri Deepak Kumar Kedia
Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

filing the appeal. 3. After hearing both the sides and perusing the averments made in the affidavit, I am satisfied that due to ‘reasonable cause’ assessee failed to file the appeal within the stipulated time. I note that the assessee has not gained from filing the appeal with a delay

Sunil Trilokchand Jain, Pune vs. CIT (Appeal), NFAC, Delhi

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

ITA 1616/PUN/2025[2022-23]Status: DisposedITAT Pune26 Aug 2025AY 2022-23

Bench: Dr.Manish Borad

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sanjay Dhivare
Section 143(2)Section 143(3)Section 250Section 68

assessee could not file the appeal before ld.CIT(A) in time and the delay of 130 days occurred in filing of appeal was for ‘reasonable cause’. Ld.CIT(A) has not condoned the appeal and the appeal has been dismissed in limine being barred by limitation. Only prayer made before ... opinion that ld.CIT(A) ought to have condoned the delay as the assessee was prevented from filing the appeal within the stipulated time for ‘reasonable cause’. I therefore in light of judgments of Hon’ble Supreme Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji

Maya Rajendra Kumbhar, Pune vs. Income Tax Officer, Ward 14(5), Pune

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

ITA 1614/PUN/2025[2012-13]Status: DisposedITAT Pune26 Aug 2025AY 2012-13

Bench: Dr.Manish Borad

For Respondent: Appellant by Shri Pratik Sandbhor
Section 144Section 147Section 250

filing of the appeal. 3. After hearing both the sides and perusing the averments made in the affidavit, I am satisfied that due to ‘reasonable cause’ assessee failed to file the appeal within the stipulated time. I therefore in light of judgments of Hon’ble Apex Court 2 Maya Rajendra ... 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 hereby set aside and effective grounds of appeal raised by the appellant are allowed for statistical purposes. 6. In the result

Saraswati Mahila Nagari Sahakari Patsanstha Maryadit, Ahilyanagar vs. ITO, Ward-2 Ahilyanagar, Ahilyanagar

In the result, appeal of the assessee is allowed as per

ITA 1044/PUN/2025[2018-19]Status: DisposedITAT Pune26 Aug 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Shri Prasad BhandariFor Respondent: Shri Sanjay Dhivare
Section 147Section 148Section 148ASection 151Section 250Section 80P

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’ assessee failed to file the appeal within the stipulated time. I therefore in light of judgments of Hon’ble Apex Court 2 Saraswati Mahila

Jagdamba Gramin Bigarsheti Sahakari Patsanstha Maryadit, A/P- Devibhoyre Tal-Parner vs. ITO Ward 2 Ahmednagar, Ahmednagar

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

ITA 1650/PUN/2024[2015-16]Status: DisposedITAT Pune26 Aug 2025AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1650/Pun/2024 िनधा"रण वष" / Assessment Year : 2015-16 Jagdamba Gramin Bigarsheti Vs. Ito, Ward-2, Ahmednagar. Sahakari Patsanstha Maryadit, A/P- Devibhoyre, Tal- Parner, Parner, Ahmednagar- 414302. Pan : Aabtj0944P Appellant Respondent Assessee By : Shri Prasad R. Kulkarni Revenue By Shri Amol Khairnar : Date Of Hearing : 21.08.2025 Date Of Pronouncement : 26.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 04.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Cooperative Society Registered Under Maharashtra State Co-Operative Societies Act. As Per Information Available With The Department The Assessee Had Deposited Cash Of Rs.1,25,61,000/- In Banks & Also Made Time Deposits Of Rs.74,31,120/-, However No Return Of Income Was Furnished By The Assessee Society.

For Appellant: Shri Prasad R. Kulkarni
Section 142(1)Section 147Section 148Section 69A

department for receiving the notices from 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. The effective grounds raised by the assessee are allowed for statistical purposes. 4. In the result, appeal

Lunkad Sky Vie Co-Operative Housing Society Limited, Pune vs. ITO Ward 7(3), Pune

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

ITA 1463/PUN/2024[2021-22]Status: DisposedITAT Pune26 Aug 2025AY 2021-22

Bench: Shri Dr. Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1463/Pun/2024 िनधा"रण वष" / Assessment Year : 2021-22 Lunkad Sky Vie Co- Vs. Ito, Ward-7(3), Pune. Operative Housing Society Limited, S. No.211, H. No.312, Lunkad Sky Vie, Lohegoan, Vimannagar, Pune- 411014. Pan : Aaaal8573A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 12.08.2025 Date Of Pronouncement : 26.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.05.2024 Passed By Ld. Addl./Jcit(A)-1, Vadodara [‘Ld. Cit(A)’] For The Assessment Year 2021-22. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “(All Grounds Are On An Alternate & Without Prejudice Basis To Each Other)

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Ramnath P. Murkunde
Section 143(1)Section 80P(2)(d)

facts of the case, we find force in the above arguments of Ld. Counsel of the assessee that the assessee was prevented by reasonable cause for not furnishing the appeal within time before Ld. CIT(A). Therefore, we deem it appropriate to set-aside the order passed

Yug Nirman Yojana Gayatri Pariwar Trust, Berhampur vs. CIT(Exemption), Hyderabad

ITA 716/HYD/2025[2025-2026]Status: DisposedITAT Hyderabad26 Aug 2025AY 2025-2026

Bench: Us:

Section 12ASection 12A(1)Section 12A(1)(ac)

made available on the statute a “Proviso” to Section 12A(1)(ac) that formally allows the CIT(Exemption) to condone the delay if reasonable cause is shown, which, thus, renders the application valid and deemed to be filed on time. We thus, in terms of our aforesaid deliberations

Raja & Co., Erode vs. ITO, Ward-2(1), Erode

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

ITA 1537/CHNY/2025[2022-23]Status: DisposedITAT Chennai26 Aug 2025AY 2022-23

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

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Mr. P.K.Senthil Kumar, Addl CIT
Section 144Section 147Section 148

proceedings against their assets. 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 appeal on or before the due date prescribed under the law and thus, in the interests of justice

Krishna Dalal, Bengaluru vs. Income Tax Officer, Ward-4(2)(3), Bangalore

In the result appeal of the assessee is hereby allowed subject to direction

ITA 974/BANG/2025[2018-19]Status: DisposedITAT Bangalore26 Aug 2025AY 2018-19

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

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department
Section 139(1)Section 143(1)Section 154Section 90

before filing the revised return of income. Therefore, the delay in filing of Form-67 was not deliberate or intentional but due to the reasonable cause. 7. However, the learned CIT(A) found that the assessee though has filed Form 67 as required under rule

Kountheya Hotels Private Limited, Chikkamagalore vs. Income Tax Officer, Ward-1, Chikmagalur

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

ITA 930/BANG/2025[2017-18]Status: DisposedITAT Bangalore26 Aug 2025AY 2017-18

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

For Appellant: Shri Abhay Jain, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department
Section 143(2)Section 41Section 43B

days. The learned CIT(A) did not condone the delay and dismissed the assessee’s appeal by holding that the assessee has not adduced reasonable cause for delay in filing of appeal. . Page 3 of 5 6. Being aggrieved by the order of the learned CIT(A), the assessee ... covid-19 pandemic and uncertainty around the pandemic also contributed to delay filing of appeal. Accordingly, the learned AR contended there was genuine and reasonable cause which prevented the assessee in filing the appeal in timely manner. However, the learned CIT(A) without considering the reasonable cause for delay

Shri. Balaji Vividodeeshagala Souharda Sahakari Sangha Niyamita, Haveri vs. Income Tax Officer, Ward-1, Haveri

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

ITA 827/BANG/2025[2019-20]Status: DisposedITAT Bangalore26 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Shri Siddhesh Nagraj Gaddi, ARFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department
Section 139(4)Section 143(1)Section 80P

assessee. 5. In the facts before us, we find that the delay is primarily attributable to lapses of the tax consultant, which constitute a reasonable cause for condonation. The assessee cannot be denied his right of appeal merely because of the fault of his representative. There is nothing on record

Muniswamy Raju, Chamarajanagar vs. ACIT, Circle-1(1) & Tps, Bangalore

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

ITA 1304/BANG/2025[2017-18]Status: DisposedITAT Bangalore26 Aug 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Subramanian, D.R
Section 143(3)Section 250Section 253(5)

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 the appeal within the prescribed time. We have gone through the reasons explained by the assessee

Arti Shailen Topiwala, Andheri West, Mumbai vs. ITO, Ward 34(1)(1), Mumbai, Bkc, Bandra East

In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for statisti...

ITA 4384/MUM/2025[2013-2014]Status: DisposedITAT Mumbai26 Aug 2025AY 2013-2014

Bench: Shri Sandeep Gosain () & Om Prakash Kant () Ita No. 4383 & 4384/Mum/2025 Assessment Year: 2013-14 Arti Shailen Topiwala Ito, Ward 34(1)(1), Mumbai B-701, Parimal Apartment, C.D. Income Tax Appellate Barfiwala Road, Andheri West, Vs. Tribunal, Mumbai- 400058 Mumbai- 400020 Pan No. Aacpt 3505 D Appellant Respondent

For Appellant: Mr. Rajesh ShahFor Respondent: Mr. Surendra Mohan –SR. DR
Section 271Section 271(1)(b)

learned CIT(A)-NFAC ought to have admitted the appeal ave admitted the appeal and condoned the delay in filing of an appeal for reasonable cause. and condoned the delay in filing of an appeal for reasonable cause. and condoned the delay in filing of an appeal for reasonable cause ... hearing and therefore there was no question of attendance before the AO. question of attendance before the AO. There was a reasonable cause for non There was a reasonable cause for non appearance before the AO. appearance before the AO. 5. The appellant craves leave to add, amend, modify, substitute

Arti Shailen Topiwala, Andheri West, Mumbai vs. ITO, Ward 34(1)(1), Mumbai, Bkc, Bandra East

In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for statisti...

ITA 4383/MUM/2025[2013-2014]Status: DisposedITAT Mumbai26 Aug 2025AY 2013-2014

Bench: Shri Sandeep Gosain () & Om Prakash Kant () Ita No. 4383 & 4384/Mum/2025 Assessment Year: 2013-14 Arti Shailen Topiwala Ito, Ward 34(1)(1), Mumbai B-701, Parimal Apartment, C.D. Income Tax Appellate Barfiwala Road, Andheri West, Vs. Tribunal, Mumbai- 400058 Mumbai- 400020 Pan No. Aacpt 3505 D Appellant Respondent

For Appellant: Mr. Rajesh ShahFor Respondent: Mr. Surendra Mohan –SR. DR
Section 271Section 271(1)(b)

learned CIT(A)-NFAC ought to have admitted the appeal ave admitted the appeal and condoned the delay in filing of an appeal for reasonable cause. and condoned the delay in filing of an appeal for reasonable cause. and condoned the delay in filing of an appeal for reasonable cause ... hearing and therefore there was no question of attendance before the AO. question of attendance before the AO. There was a reasonable cause for non There was a reasonable cause for non appearance before the AO. appearance before the AO. 5. The appellant craves leave to add, amend, modify, substitute

Agriwise Finserv Limited, Andheri, Mumbai vs. DCIT Circle-3(2)(1), Churchgate, Mumbai

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

ITA 4381/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Aug 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Om Prakash Kantagriwise Finserv Ltd Vs. Dcit, Circle – 3(2)(1) Aayakar Bhavan, Unit No. 802, 8Th Floor, Churchgate, Mumbai – Sumer Plaza, Marol 400020. Maroshi Road, Jb Nagar, So, Mumbai – 400059. Pan/Gir No. Aabcr0038F (Applicant) (Respondent) Assessee By Shri Bhupendra Shah Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 26.08.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 07.07.2023 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre / Cit(A), Mumbai For The Assessment Year 2012- 13. 2. At The Outset, We Noticed That The Present Appeal Filed By The Assessee Is Time Barred By 611 Days & In This Regard An Application For Seeking Condonation Of Delay Has Been Filed By The Assessee, Wherein It Has Been Mentioned As Under:

Section 143(3)Section 250Section 5

raised by the assessee and taking into consideration the facts narrated before us and while taking a lenient view we find 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