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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

Spice Dealcomm Pvt. Ltd., Kolkata vs. ACIT (OSD), Ward-1(3), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 2428/KOL/2024[2011-12]Status: DisposedITAT Kolkata30 Jul 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2428/Kol/2024 Assessment Year: 2011-12 Spice Dealcomm Pvt. Ltd.……...……..…………………....Appellant Dc-9/28, Shastri Bagan, Deshbandhu Nagar, W.B. – 700059. [Pan: Aapcs1202G] Vs. Acit (Osd), Ward-1(3), Kolkata.………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Manas Mondal, Acit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 24, 2025 Date Of Pronouncing The Order : July 30, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 25.01.2023 Passed By The Nfac [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 616 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.

Section 147Section 148Section 250Section 250(6)Section 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. I.T.A. No.2428/Kol/2024 Spice Dealcomm

Madras Port and Dock Educational Trust Higher Sec. School, Chennai vs. ITO, Exemptions Ward-2, Chennai

In the result both the appeals of the assessee for the A

ITA 938/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Jul 2025AY 2022-23

Bench: Shri George George K & Shri S.R. Raghunathaआयकरअपीलसं./Ita Nos.:937 & 938/Chny/2025 धनि््रणवर्/ Assessment Years: 2021-22 & 2022-23 Chennai Port & Dock Educational Ito, Trust Higher Secondary School Vs. Exemptions Ward-2, (Formerly Known As Madras Port & Chennai – 600 034. Dock Educational Trust Higher Secondary School), Mdlb Housing Colony, Tondiarpet, Chennai – 600 081. [Pan:Aaaam-8192-L] (अपील्थ्/Appellant) (प्थ्/Respondent) अपील्थ्कीओरसे/Appellant By : Shri. Suraj Nahar, C.A. प्थ्कीओरसे/Respondent By : Shri. Kumar Chandan, J.C.I.T. सुनव््कीत्रीख/Date Of Hearing : 17.06.2025 घोरण्कीत्रीख/Date Of Pronouncement : 30.07.2025

For Appellant: Shri. Suraj Nahar, C.AFor Respondent: Shri. Kumar Chandan, J.C.I.T
Section 11Section 12ASection 143(1)Section 234BSection 250

there is a delay of 1 day in appeals filed by the assessee. After hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeals on or before the due date prescribed under the law and thus, in the interests of justice ... date prescribed under the Income Tax Act. 4. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had reasonable cause for non-filing of audit report in Form No. 10B within the prescribed due date. 5. For that the Commissioner of Income Tax (Appeals) failed

Madras Port and Dock Educational Trust Higher Secondary School, Chennai vs. ITO, Exemption Ward-2, Chennai

In the result both the appeals of the assessee for the A

ITA 937/CHNY/2025[2021-22]Status: DisposedITAT Chennai30 Jul 2025AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunathaआयकरअपीलसं./Ita Nos.:937 & 938/Chny/2025 धनि््रणवर्/ Assessment Years: 2021-22 & 2022-23 Chennai Port & Dock Educational Ito, Trust Higher Secondary School Vs. Exemptions Ward-2, (Formerly Known As Madras Port & Chennai – 600 034. Dock Educational Trust Higher Secondary School), Mdlb Housing Colony, Tondiarpet, Chennai – 600 081. [Pan:Aaaam-8192-L] (अपील्थ्/Appellant) (प्थ्/Respondent) अपील्थ्कीओरसे/Appellant By : Shri. Suraj Nahar, C.A. प्थ्कीओरसे/Respondent By : Shri. Kumar Chandan, J.C.I.T. सुनव््कीत्रीख/Date Of Hearing : 17.06.2025 घोरण्कीत्रीख/Date Of Pronouncement : 30.07.2025

For Appellant: Shri. Suraj Nahar, C.AFor Respondent: Shri. Kumar Chandan, J.C.I.T
Section 11Section 12ASection 143(1)Section 234BSection 250

there is a delay of 1 day in appeals filed by the assessee. After hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeals on or before the due date prescribed under the law and thus, in the interests of justice ... date prescribed under the Income Tax Act. 4. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had reasonable cause for non-filing of audit report in Form No. 10B within the prescribed due date. 5. For that the Commissioner of Income Tax (Appeals) failed

Thottiapatti Muthusamy Mohan, Namakkal vs. The Income Tax Officer, Circle-1, Namakkal

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

ITA 1327/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Jul 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1327/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Thottiapatti Muthusamy Mohan, Vs. The Income Tax Officer, 629, Salem Road, Circle 1, Namakkal 637 001. Namakkal. [Pan:Aldpm2174M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.S. Lakshmi Venkataraman, F.C.A. ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.03.2025 Passed By The Addl/Jcit(A)-13, Mumbai For The Assessment Year 2016-17. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer By Passing Exparte Order In The Facts & Circumstances Of The Case.

For Appellant: Shri T.S. Lakshmi Venkataraman, F.C.AFor Respondent: Ms. V. Supraja, Addl.CIT
Section 143(1)Section 143(2)Section 194CSection 253(6)

perusal of para 5.1 of the impugned order, we note that before the ld. CIT(A), the assessee has explained reasonable cause for the delay in filing the appeal before the ld. CIT(A). Considering the reasonable cause for the delay in filing the appeal, the delay of 146 days

Shri Guru Gajadandeshwara Charitable Trust, Devarabhupur, Lingasagur vs. The Income Tax Officer, Exemption, Exemption Ward-1, Kalburgi

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

ITA 502/BANG/2025[2025-26]Status: DisposedITAT Bangalore30 Jul 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: Na Shri Guru Gajadandeshwara Charitable Trust 1 Devarabhupur Post Devabhupur Cit (Exemption) Lingasugur Vs. Ward-1 Raichur 584 139 Kalburgi Karnataka Pan No : Aazts9450P Appellant Respondent Appellant By : Sri Ramanagowda S Gowdari, A.R. Respondent By : Sri Sridhar E., D.R. Date Of Hearing : 15.05.2025 Date Of Pronouncement : 30.07.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit (Exemption) Dated 26.9.2024 Vide Din & Order No. Itba/Exm/F/Exm45/2024-25/1069118346(1) Cancelling The Approval U/S 80G Of The Act Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sri Ramanagowda S Gowdari, A.RFor Respondent: Sri Sridhar E., D.R
Section 253(5)Section 80G

assessee for not presenting the appeals within the prescribed time. The explanation therefore, becomes relevant to determine whether the same reflect sufficient and reasonable cause on the part of the assessee in not filing these appeals within the prescribed time. We have gone through the cause explained by the assessee ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for not filing the appeal. We have to see the cause of the delay. When there was a sufficient cause, the period of delay

Vardhman Infra Developers (P) Ltd., Delhi vs. Income Tax Officer Ward-78(3), New Delhi, Delhi

In the result, the assessee’s appeal is allowed

ITA 511/DEL/2024[2014-15]Status: DisposedITAT Delhi30 Jul 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.511/Del./2024, A.Y. 2014-15 Vardhman Infra Developers Income Tax Officer, (P) Ltd., 401-414, C-58, Ward-78(3), 4Th Floor, Shahpuri, Vs. Income Tax Office, Tirath Singh, Tower Dda, Laxmi Nagar, New Delhi Janakpuri, New Delhi Pan: Aadcv3838M (Appellant) (Respondent) Appellant By None Respondent By Shri Om Prakash, Sr. Dr Date Of Hearing 30/07/2025 Date Of Pronouncement 30/07/2025 Order Per Avdhesh Kumar Mishra, Am The Appeal For The Assessment Year (‘Ay’) 2014-15 Filed By The Assessee Is Directed Against The Order Dated 18.03.2019 Of The Commissioner Of Income Tax (Appeals)-28, New Delhi [‘Cit(A)’].

Section 201Section 203Section 272A(2)(g)Section 273Section 276BSection 279(2)

confirming the penalty rejecting the contention of the appellant that delay in issuance of TDS certificate was on account of a reasonable cause in terms of provision of Section 273В, as such the penalty is not leviable. Vardhman Infra Developers (P) Ltd. 3. On the facts and circumstances ... offence of late deposit of TDS after deduction of tax punishable under section 276B of the Act. Therefore, it submitted that there was reasonable cause for late issuance of TDS Certificates. It was also brought to the notice Range Head-TDS that the offence punishable under section 276B