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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

Palani Ragavendran, Tiruvannamalai vs. ITO, Ward-1, Tiruvannamalai

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

ITA 4026/CHNY/2025[2020-21]Status: DisposedITAT Chennai18 Feb 2026AY 2020-21

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 4026/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Shri Palani Ragavendran, The Income Tax Officer, No.10/43, Kumara Koil Street, Vs. Ward 1, Tiruvannamalai – 606 601. Tiruvannamalai Pan: Bfzpr 9478E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Dr. Abhishek Murali, Ca ""यथ" क" ओर से/Respondent By : Ms. V Awasthy, Jcit सुनवाई क" तारीख/Date Of Hearing : 17.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 18.02.2026

For Appellant: Dr. Abhishek Murali, CAFor Respondent: Ms. V Awasthy, JCIT
Section 147Section 250

adjudicating on merits. The FAA held that there is a delay of 116 days in filing the appeal before him 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 ... which resulted in delay of 117 days. However, the FAA rejected the assessee’s request for condonation by holding that there is no reasonable cause and dismissed the appeal of the assessee. In our view, the reason cited by assessee before FAA seems quite reasonable and hence, we condone

Imtiyaz Ahmad Khan, Mumbai vs. ITO Ward 41(1)(2), Mumbai

In the result, the appeal filed by the assessee stands allowed for statistical purpose

ITA 7683/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarimtiyaz Ahmad Khan Vs. Fao- Faceless 212, New Bharat Assessment Centre, Compound, Near Kalpana Delhi/ Talkies, Near Baxi Singh Ito, Ward 41(1)(2), Petrol Pump, L.B.S. Marg, Kautilya Bhavan, Kurla, (West), Mumbai Bandra Kurla Complex, 400070 Mumbai - 400051 Pan/Gir No. Bkzpk033E (Applicant) (Respondent) Assessee By Shri Mohammed Shadab Revenue By Shri Brajendra Kumar (Sr. Dr.) Date Of Hearing 11.02.2026 Date Of Pronouncement 18.02.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 17.10.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2018-19. The Following Grounds Are Reproduced Below: “1 On The Facts & In The Circumstances Of The Case & In Law, That The Id. Cit(A) Has Seriously Erred In Law & On The Facts & It In The Circumstances Of The Case In 2 Imtiyaz Ahmand Khan

Section 143(3)Section 250

holding that the assessee could not furnish the documentary evidences to explain the delay in filing appeal and also could not establish the reasonable cause in filing the appeal. 4. Whereas on the contrary ld. AR submitted that the assessee had furnished all the required documents and is still ready