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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

Three Seasons Exim Limited, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

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

ITA 94/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnanआ.अपी.सं /Ita No.94/Viz/2025 (िनधा"रण वष"/Assessment Year: 2028-19 ) Three Season Exim Ltd Vs. Income Tax Officer Kakinada Ward-1 Pan:Aafct1751M Kakinada (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G.V.N. Hari, Advocate राज" व "ारा/Revenue By:: Dr. Satyasai Rath, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 17/07/2025 घोषणा की तारीख/Pronouncement: 25/07/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated 29/02/2024 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2018-19. 2. There Is A Delay Of 291 Days In Filing The Present Appeal Before This Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Which Is Also Supported By An Affidavit Duly Signed By The Director Of The Assessee Company. The Learned Ar Of Page 1 Of 8

For Appellant: Shri G.V.N. Hari, AdvocateFor Respondent: : Dr. Satyasai Rath, CIT(DR)

submitted that the delay of 291 days is an inordinate delay in filing the appeal and the assessee has failed to explain any reasonable cause for the delay. 4. We have considered the rival contentions as well as the relevant material available on record. The appeal before the learned

Dinesh Baranwal, East Champaran vs. ITO, Ward-1(3), Motihari

In the result, the appeal of the assessee is stand allowed

ITA 593/PAT/2024[2012-13]Status: HeardITAT Patna24 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.593/Pat/2024 Assessment Year: 2012-13 Sri Dinesh Baranwal……………….....…..…………………....Appellant C/ M/S Salarpuria Jajodia & Co., 7, C. R Avenue, 3Rd Floor, Kol-72. [Pan: Adkpg6603N] Vs. Ito, Ward-1(3), Motihari…...……….…............................…..…..... Respondent Appearances By: Shri Siddharth Jhajharia, Fca, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 24 , 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Has Been Filed By The Assessee Against The Order Dated 24.05.2024 Passed By The Nfac For The Assessment Year 2012-13. 2. At The Outset, It Is Noted That There Is A Delay Of 57 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 The Assessee Was A Dealer Of A Telecom Service Operator, Namely M/S Unitech Wireless Tamil Nadu Pvt.

Section 143(1)Section 147Section 148Section 271(1)(C)Section 271(1)(c)Section 44A

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

Jora Singh, Village Jodhpur (Barnala) vs. Income Tax Officer Ward Barnala, Barnala

In the result, both the appeals are allowed for statistical purposes

ITA 407/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh24 Jul 2025AY 2021-22

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 406 & 407/Chd/2025 "नधा"रण वष" / Assessment Year : 2021-22 Jora Singh, The Ito, S/O Sh. Gurdev Singh, बनाम Ward, Vill. Jodhpur (Barnala) Barnala Vs. (Rural 1), Barnala Kty, S.O.Barnala, Punjab 148101 "थायी लेखा सं./ Pan No: Gtups0945H अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 23.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 24.07.2025 आदेश/Order Per Krinwant Sahay, Am: Captioned Appeals Have Been Filed By The Assessee Against The Separate Orders Each Dated 21.12.2024 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Vivek Vardhan, Addl. CIT, Sr.DR
Section 144Section 144B

that the orders passed by the Assessing Officer and CIT(A) are ex-parte order and the Assessee was prevented by sufficient and reasonable cause in not attending the proceedings before Ld. CIT(A) as the e.mails for hearing sent by the Department have been oversighted by the authorized representative

Jora Singh, Village Jodhpur Barnala vs. ITO Barnala, Barnala

In the result, both the appeals are allowed for statistical purposes

ITA 406/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh24 Jul 2025AY 2021-22

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 406 & 407/Chd/2025 "नधा"रण वष" / Assessment Year : 2021-22 Jora Singh, The Ito, S/O Sh. Gurdev Singh, बनाम Ward, Vill. Jodhpur (Barnala) Barnala Vs. (Rural 1), Barnala Kty, S.O.Barnala, Punjab 148101 "थायी लेखा सं./ Pan No: Gtups0945H अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 23.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 24.07.2025 आदेश/Order Per Krinwant Sahay, Am: Captioned Appeals Have Been Filed By The Assessee Against The Separate Orders Each Dated 21.12.2024 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Vivek Vardhan, Addl. CIT, Sr.DR
Section 144Section 144B

that the orders passed by the Assessing Officer and CIT(A) are ex-parte order and the Assessee was prevented by sufficient and reasonable cause in not attending the proceedings before Ld. CIT(A) as the e.mails for hearing sent by the Department have been oversighted by the authorized representative