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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

Gunnebo India Employees Provident Fund, Mumbai vs. ITO Ward 1(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 4193/MUM/2025[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2016-17 Gunnebo India Employees Income Tax Officer, Provident Fund, Ward-1(1), Unit No.2, 1St Floor, Vs. Thane-400601. Akruti Smc, Next To Msrtc Depot, Lbs Marg, Khopat, Thane (W), Mumbai-400601. Pan : Aaaas5921K (Appellant) (Respondent) For Assessee : Ms. Hemlata Bhungare For Revenue : Shri Surendra Mohan, Sr.Dr Date Of Hearing : 30-07-2025 Date Of Pronouncement : 31-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl./Jcit(A)-8, Delhi [„Ld.Cit(A)‟], Dated 28-02-2025, Pertaining To Assessment Year (Ay) 2016-17. 2. At The Outset, It Is Noted That There Is A Delay Of 54 Days In Filing The Appeal As Pointed Out By The Registry. After Hearing Both The Parties & Taking Into Consideration The Affidavit Placed On Record Seeking Condonation Of Delay, We Find That There Was Reasonable Cause For The Delay

For Appellant: Ms. Hemlata BhungareFor Respondent: Shri Surendra Mohan, Sr.DR
Section 10(25)Section 143(3)

Registry. After hearing both the parties and taking into consideration the affidavit placed on record seeking condonation of delay, we find that there was reasonable cause for the delay 2 in filing the present appeal and hence, the delay is hereby condoned and appeal is admitted for adjudication. 3. During

Late Bhauso Gunda Patil Legal Heir Shri Shashikant Patil, Tasgaon vs. ITO, Ward 4, Sangli

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

ITA 647/PUN/2025[2012-13]Status: DisposedITAT Pune30 Jul 2025AY 2012-13

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.647/Pun/2025 िनधा"रण वष" / Assessment Year: 2012-13 Late Bhauso Gunda Patil Legal V The Income Tax Officer, Heir Shri Shashikant Patil, S Ward-4, Sangli. At Post Khatav Brahmanal, Tal-Tasgaon, Maharashtra- 416423. Pan: Apipp7148F Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Eknath Abhang –Addl.Cit(Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 30/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Shri Shashikant Patil As Legal Heir Of Late Bhauso Gunda Patil Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2012-13 Dated 26.10.2023, Emanating From Order U/S.144 Of The Income Tax Act, 1961, Dated 28.11.2019. The Assessee Has Raised Following Grounds Of Appeal :

Section 144Section 250Section 69A

Delay. We have perused the Affidavit. Substantial justice is more important than procedural delay. Therefore, we are convinced that there was sufficient and reasonable cause for delay. Hence, the Delay is condoned. Order pronounced in the open Court on 30 July, 2025. VINAY BHAMORE Dr.DIPAK P. RIPOTE JUDICIAL MEMBER ACCOUNTANT