What is 426 (Rajasthan) 14. Woodword Governors India v. CIT authority for?

Limitation for assessment proceedings is to be counted from the end of the financial year in which the assessment order is passed, not from the date of lifting prohibitory orders.

426 (Rajasthan) 14. Woodword Governors India v. CIT (253 ITR 745)

Q: How many judgments cite 426 (Rajasthan) 14. Woodword Governors India v. CIT?

45 judgments on BharatTax cite 426 (Rajasthan) 14. Woodword Governors India v. CIT (253 ITR 745), spanning 2008 to 2025.

Ramesh Kumar, Jhunjhunu vs. ITO Ward-1, Jhunjhunu

In the result, all the appeals of the assessee are allowed

ITA 1182/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 115BSection 147Section 148Section 151Section 234ASection 250Section 69

…e was reasonable cause for the said failure of not complying with the notice served on them under sub-section (1) of section 142 of the Act. The meaning of reasonable cause has been stated in the case of Woodward Governor India P. Ltd. Vs. CIT and ors. (2002) 253 ITR 745 (Delhi) para 5 & 6, is reproduced below:- "What would constitute reasonable cause cannot be laid down with precision. It would depend upon factual background and the scope for extremely limited and unless the conclusions are perverse based on conjectures or surmises and/ or have been arrived at without consideration of relevant material and/or ha…

Ramesh Kumar, Jhunjhunu vs. ITO Ward-1 Jhunjhunu, Jhunjhunu

In the result, all the appeals of the assessee are allowed

ITA 1180/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 115BSection 144Section 147Section 148Section 151Section 234ASection 250Section 69

…e was reasonable cause for the said failure of not complying with the notice served on them under sub-section (1) of section 142 of the Act. The meaning of reasonable cause has been stated in the case of Woodward Governor India P. Ltd. Vs. CIT and ors. (2002) 253 ITR 745 (Delhi) para 5 & 6, is reproduced below:- "What would constitute reasonable cause cannot be laid down with precision. It would depend upon factual background and the scope for extremely limited and unless the conclusions are perverse based on conjectures or surmises and/ or have been arrived at without consideration of relevant material and/or ha…

Branch Manager State Bank of India, Regional Business Office, Administretive Office, Kanpur vs. ACIT (TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 491/LKW/2024[2017-18]Status: DisposedITAT Lucknow24 Apr 2025AY 2017-18

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

…an of average intelligence and ordinary prudence, acting under normal circumstances, without negligence or inaction or want of bona fides.' 6.6 The same Division Bench of the Delhi High Court in its judgment in Woodward Governor India (P.) Ltd. v. CIT [2002] 253 ITR 745/[2001] 118 Taxman 433 held thus: "Reasonable cause" as applied to human action is that which would constrain a person of average intelligence and ordinary prudence. It can be described as probable cause. It means an honest bellef founded upon reasonable grounds, of the existence of a state of circumstances, which assuming them to be true, would…

Branch Manager State Bank of India, Regional Business Office, Administretive Office, Kanpur vs. ACIT (TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 490/LKW/2024[2016-17]Status: DisposedITAT Lucknow24 Apr 2025AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

…man of average intelligence and ordinary prudence, acting under normal circumstances, without negligence or inaction or want of bona fides.' 6.6 The same Division Bench of the Delhi High Court in its judgment in Woodward Governor India (P.) Ltd. v. CIT [2002] 253 ITR 745/[2001] 118 Taxman 433 held thus: "Reasonable cause" as applied to human action is that which would constrain a person of average intelligence and ordinary prudence. It can be described as probable cause. It means an honest bellef founded upon reasonable grounds, of the existence of a state of circumstances, which assuming them to be true, would r…

State Bank of India, Overseas Branch, Kanpur vs. ACIT(TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 488/LKW/2024[2016-17]Status: DisposedITAT Lucknow24 Apr 2025AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

…s a man of average intelligence and ordinary prudence, acting under normal circumstances, without negligence or inaction or want of bona fides.' The same Division Bench of the Delhi High Court in its judgment in Woodward Governor India (P.) Ltd. v. CIT [2002] 253 ITR 745/[2001] 118 Taxman 433 held thus: "Reasonable cause" as applied to human action is that which would constrain a person of average intelligence and ordinary prudence. It can be described as probable cause. It means an honest bellef founded upon reasonable grounds, of the existence of a state of circumstances, which assuming them to be true, would r…

State Bank of India, Overseas Branch, Kanpur vs. ACIT(TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 487/LKW/2024[2015-16]Status: DisposedITAT Lucknow24 Apr 2025AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

…an of average intelligence and ordinary prudence, acting under normal circumstances, without negligence or inaction or want of bona fides.' 6.6 The same Division Bench of the Delhi High Court in its judgment in Woodward Governor India (P.) Ltd. v. CIT [2002] 253 ITR 745/[2001] 118 Taxman 433 held thus: "Reasonable cause" as applied to human action is that which would constrain a person of average intelligence and ordinary prudence. It can be described as probable cause. It means an honest bellef founded upon reasonable grounds, of the existence of a state of circumstances, which assuming them to be true, would…

The Commissioner of Income Tax vs. M/S Jindal Tractebel Power Co Ltd

ITA/1184/2006HC Karnataka03 Feb 2025

Bench: KRISHNA S DIXIT,G BASAVARAJA

Section 201Section 201(1)Section 260ASection 271Section 271CSection 273

…he assessee or other person as regards the reason for failure was on account of a reasonable cause, and non-consideration of assessee’s explanation would vitiate the order. Bona fide belief 4 (2002) 253 ITR 745 DEL - 9 - NC: 2025:KHC:4829-DB ITA No. 1184 of 2006 coupled with the genuineness of the transactions would constitute a reasonable cause. In Woodward supra the court also considered the meaning of ‘reasonable cause’ and held: “Reasonable cause’ as applied to human action is that which would constrain a person of average in…

Dayaram Yadav, Jaipur vs. CIT(A), NFAC

In the result, appeal of the assessee is allowed

ITA 382/JPR/2022[2010-11]Status: DisposedITAT Jaipur28 Mar 2023AY 2010-11

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

For Appellant: Shri C. L. Yadav (C.A.) &For Respondent: Smt Monisha Choudhary (Addl. CIT) a

Section 253Section 253(5)Section 271(1)(b)

…imposed, if the assessee is able to prove that there was reasonable cause for the said failure of not complying with the notice served on them. The meaning of reasonable cause has been discussed in the case of Woodward Governor India P. Ltd. Vs. CIT and Ors. 253 ITR 745 (Delhi). The relevant portion, as contained in Para 5 and 6, is reproduced below:- "What would constitute reasonable cause cannot be laid down with precision. It would depend upon factual background and the scope is extremely limited and unless the conclusions are perverse based on conjectures or surmises and/ or have been arrived at without con…

Karnataka Agrochemical Pvt Ltd, Bangalore vs. Additional Commissioner of Income Tax Range-4(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 98/BANG/2022[2013-14]Status: DisposedITAT Bangalore29 Apr 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

For Appellant: Shri SreeHariKutsa, AdvocateFor Respondent: Shri Priyadarshi Mishra, Jt.CIT(DR)(ITAT), Bengaluru

Section 250Section 269TSection 271E

…ents a man of average intelligence and ordinary prudence, acting under normal circumstances, without negligence or inaction or want of bona fides." 20. The Hon'ble Delhi High Court in the matter of Woodward Governers India (P.) Ltd., v. CIT reported in [2002] 253 ITR 745 (Delhi) has Page 10 of 37 laid down the following in respect of reasonable cause for the purpose of Section 273B. The Hon'ble Court held as under — "5. Section 273B starts with a non obstante clause and provides that notwithstanding anything contained in several provisions enumerated therein including section 271C, no penalty shall be imposable…

Vamita Singh, Jaipur vs. ITO, Balotra

In the result, appeal of the assessee is allowed

ITA 87/JODH/2019[2011-12]Status: DisposedITAT Jodhpur22 Feb 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 87/Jodh/2019 Fu/Kzkj.K O"Kz@Assessment Year :2011-12 Vamita Singh, Cuke Ito, Vs. C/O-Ashok Kumar Bansal, C.A., Ward-7(3) 2Nd Vijay Shanti Plaza, Near Jaipur. Railway Crossing, Balotra-344022. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Atzps 9372 B Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Ashok Kumar Bansal (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Monisha Choudhary(Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 22/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 24/02/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-3, Jaipur Dated 20/11/2018 For The A.Y. 2011-12. 2. The Hearing Of The Appeal Was Concluded Through Video Conference In View Of The Prevailing Situation Of Covid-19 Pandemic.

For Appellant: Shri Ashok Kumar Bansal (CA)For Respondent: Smt. Monisha Choudhary(Addl.CIT)

Section 142(1)Section 143(2)Section 143(3)Section 271(1)(b)

…issued was only because of ‘non-receipt of the notices’ by the assessee and therefore, in our considered view, the same was a “reasonable cause” as has also been held by the Hon’ble Delhi High Court in the case of Woodward Governor Nidia P Ltd. Vs CIT (2002) 253 ITR 745 (Delhi) wherein it was held that levy of penalty is not automatic and the absence of a ‘reasonable cause’ is necessary. 13. Further, the Coordinate Bench of Indore ITAT, in the case of M.P. State Civil Supplies Corporation Ltd. Vs ACIT in ITA No. 713/Ind/2015, 2016 Tax Pub (DT) 4071 (Ind-Trib) has held as under: “that power to levy the penalty…