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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

Shiva Kesava Mahasannidhanam Kokapeta, Ranga Reddy vs. CIT (Exemption), Hyderabad

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

ITA 930/HYD/2025[-]Status: DisposedITAT Hyderabad13 Aug 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.929 & 930/Hyd/2025 (िनधा"रण वष"/Assessment Year: Na) Shiva Kesava Vs. Cit (Exemptions) Mahasannidhanan, Hyderabad Kokapeta, R.R. Distt. Pan:Aamts0303E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Pawan Kumar Chakrapani, Ca राज" व "ारा/Revenue By:: Shri Ravindra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 12/08/2025 घोषणा की तारीख/Pronouncement: 13/08/2025 आदेश/Order Per Vijay Pal Raothese 2 Appeals By The Assessee Are Directed Against The Separate Orders Of The Learned Cit (Exemptions), Hyderabad Both Dated, 20/11/2024 Whereby The Application Of The Assessee For Registration U/S 12Ab & Approval U/S 80G(5) Of The I.T. Act Were Dismissed.

For Appellant: Shri Pawan Kumar Chakrapani, CAFor Respondent: : Shri Ravindra Kumar Naik, CIT(DR)
Section 12ASection 80GSection 80G(5)

assessee to the notice issued by it. Therefore, in the facts and circumstances of the case, we are satisfied that there was a reasonable cause of delay in filing the appeals and further the impugned orders were passed without considering the relevant record and reply filed by the assessee. Accordingly

Shiva Kesava Mahasannidhanam Kokapeta, Ranga Reddy vs. CIT(Exemption), Hyderabad

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

ITA 929/HYD/2025[-]Status: DisposedITAT Hyderabad13 Aug 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.929 & 930/Hyd/2025 (िनधा"रण वष"/Assessment Year: Na) Shiva Kesava Vs. Cit (Exemptions) Mahasannidhanan, Hyderabad Kokapeta, R.R. Distt. Pan:Aamts0303E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Pawan Kumar Chakrapani, Ca राज" व "ारा/Revenue By:: Shri Ravindra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 12/08/2025 घोषणा की तारीख/Pronouncement: 13/08/2025 आदेश/Order Per Vijay Pal Raothese 2 Appeals By The Assessee Are Directed Against The Separate Orders Of The Learned Cit (Exemptions), Hyderabad Both Dated, 20/11/2024 Whereby The Application Of The Assessee For Registration U/S 12Ab & Approval U/S 80G(5) Of The I.T. Act Were Dismissed.

For Appellant: Shri Pawan Kumar Chakrapani, CAFor Respondent: : Shri Ravindra Kumar Naik, CIT(DR)
Section 12ASection 80GSection 80G(5)

assessee to the notice issued by it. Therefore, in the facts and circumstances of the case, we are satisfied that there was a reasonable cause of delay in filing the appeals and further the impugned orders were passed without considering the relevant record and reply filed by the assessee. Accordingly

Highgrowth Vyapaar Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

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

ITA 1022/KOL/2025[2011-2012]Status: DisposedITAT Kolkata13 Aug 2025AY 2011-2012

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1022/Kol/2025 Assessment Year: 2011-12 Highgrowth Vyapaar Pvt. Ltd…………..……..…………………....Appellant 42E, Cornfield Road, Ground Floor, Ballygunge, Kol-19. [Pan: Aacch0203R] Vs. Ito, Ward-12(1), Kolkata..…………....…..………………….…..... Respondent Appearances By: Shri Avijit Ghoshal, Advocate, Appeared On Behalf Of The Appellant. Shri Soumitra Ghosh, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 28, 2025 Date Of Pronouncing The Order : August 13, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre Dated 15.03.2024 Passed Against The Assessment Order Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2011–12. 2. At The Outset, It Is Noted That There Is A Delay Of 347 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. 3. Brief Facts Of The Case Are That In The Case Of The Assessee, The Return Of Income Was Filed On 18.03.13 Disclosing A Loss Of Rs.11,281/-.

Section 143(1)Section 143(2)Section 147Section 250Section 68

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. 3. Brief facts