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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

Dayanand Foundation, Pune vs. CIT Exemption, Pune

In the result ITA No. 2330/PUN/2024 is allowed for statistical purposes and ITA No

ITA 2542/PUN/2024[-]Status: DisposedITAT Pune06 Aug 2025

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2330&2542/Pun/2024 धििाारण वर्ा / Assessment Year: Na Dayanand Foundation, Cit Exemption, Pune G Wing, Flat No. 501, Sr No.136/1A, 5A, 5B Marvel, Vs. Hadapsar Pune-411028 Maharashtra Pan-Aactd9309F अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Smt. Deepa Khare (Through Virtual) Department By: Shri Amol Khairnar Cit-Dr Date Of Hearing: 06-08-2025 Date Of Pronouncement: 12-08-2025 आदेश / Order Per Dr. Manish Borad:- The Captioned Appeals At The Instance Of Assessee Are Directed Against The Order Dated 20.03.2024 & 16.11.2024 Passed By Ld.Cit(E), Pune Under Second Proviso To Section 80G(5) Of The Income-Tax Act, 1961. 2. Registry Has Informed That Ita 2330/Pun/2024 Has Been Filed With A Delay Of 166 Days. Affidavit Along With Application For Condonation Of Delay Is Placed On Record. Perusal Of The Same Indicates That Assessee Was Prevented By Reasonable Cause For Not Filing The Appeal Within The Prescribed Time Limit. Placing Reliance On The Judgement Of Hon’Ble Apex Court In The Case Of Collector, Land Acquisition Vs. Master Katiji & Others(1987) 167 Itr 471(Sc) (Supreme Court) & In The Case Of Inder Singh Vs State Of Madhya Pradesh Judgement Dated 21.03.2025 (2025) Insc 382) & Also Taking A Liberal & Justice Oriented Approach The Delay In Filing The Appeal In Ita No. 2330/Pun/2024 Is Condoned & The Appeal Is Admitted For Adjudication.

For Appellant: Smt. Deepa Khare (through virtual)For Respondent: Shri Amol Khairnar CIT-DR
Section 12ASection 80G(5)

days. Affidavit along with application for condonation of delay is placed on record. Perusal of the same indicates that assessee was prevented by reasonable cause for not filing the appeal within the prescribed time limit. Placing reliance on the judgement of Hon’ble Apex Court in the case of Collector

Dayanand Foudation, Pune vs. CIT Exemption, Pune

In the result ITA No. 2330/PUN/2024 is allowed for statistical purposes and ITA No

ITA 2330/PUN/2024[-]Status: DisposedITAT Pune06 Aug 2025

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2330&2542/Pun/2024 धििाारण वर्ा / Assessment Year: Na Dayanand Foundation, Cit Exemption, Pune G Wing, Flat No. 501, Sr No.136/1A, 5A, 5B Marvel, Vs. Hadapsar Pune-411028 Maharashtra Pan-Aactd9309F अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Smt. Deepa Khare (Through Virtual) Department By: Shri Amol Khairnar Cit-Dr Date Of Hearing: 06-08-2025 Date Of Pronouncement: 12-08-2025 आदेश / Order Per Dr. Manish Borad:- The Captioned Appeals At The Instance Of Assessee Are Directed Against The Order Dated 20.03.2024 & 16.11.2024 Passed By Ld.Cit(E), Pune Under Second Proviso To Section 80G(5) Of The Income-Tax Act, 1961. 2. Registry Has Informed That Ita 2330/Pun/2024 Has Been Filed With A Delay Of 166 Days. Affidavit Along With Application For Condonation Of Delay Is Placed On Record. Perusal Of The Same Indicates That Assessee Was Prevented By Reasonable Cause For Not Filing The Appeal Within The Prescribed Time Limit. Placing Reliance On The Judgement Of Hon’Ble Apex Court In The Case Of Collector, Land Acquisition Vs. Master Katiji & Others(1987) 167 Itr 471(Sc) (Supreme Court) & In The Case Of Inder Singh Vs State Of Madhya Pradesh Judgement Dated 21.03.2025 (2025) Insc 382) & Also Taking A Liberal & Justice Oriented Approach The Delay In Filing The Appeal In Ita No. 2330/Pun/2024 Is Condoned & The Appeal Is Admitted For Adjudication.

For Appellant: Smt. Deepa Khare (through virtual)For Respondent: Shri Amol Khairnar CIT-DR
Section 12ASection 80G(5)

days. Affidavit along with application for condonation of delay is placed on record. Perusal of the same indicates that assessee was prevented by reasonable cause for not filing the appeal within the prescribed time limit. Placing reliance on the judgement of Hon’ble Apex Court in the case of Collector