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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

The Kangazha Service Co Operative Bank Limited, Kangazha vs. Income Tax Officer Ward 2 Thiruvalla, Thiruvalla

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

ITA 414/COCH/2025[2018-19]Status: DisposedITAT Cochin15 Jul 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2018-19 Kangazha Service Co-Op. Bank Ltd. .......... Appellant Kangazha P.O., Kottayam 686541 [Pan: Aadat7325H] Vs. The Income Tax Officer, Wd-2, Thiruvalla .......... Respondent Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 13.06.2025 Date Of Pronouncement: 15.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 03.10.2023 For Assessment Year (Ay) 2018-19. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Return Of 2 Kangazha Service Co-Op. Bank Ltd. Income For Ay 2018-19 Was Filed On 26.09.2018 Declaring Nil Income After Claiming Deduction U/S. 80P Of The Income Tax Act, 1961 (The Act) Of Rs. 1,49,79,478/-. Against The Said Return Of Income, The Assessment Was Completed By The Ito, Ward-2, Thiruvalla (Hereinafter Called "The Ao") Vide Order Dated 23.03.2021 Passed U/S. 143(3) R.W.S. 143(3A) & 143(3B) Of The Act At A Total Income Of Rs. 1,49,70,478/-. While Doing So, The Ao Denied Deduction U/S. 80P By Holding That The Appellant Society Is Engaged In Activities Other Than The Activities For Which It Was Formed.

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 154Section 250(6)Section 80P

condonation of delay, in the absence of any evidence contrary, we are of the considered opinion that the appellant society is prevented by sufficient reasonable cause in filing the appeal within the prescribed limit. Accordingly, we condone the delay and admit the appeal for adjudication. 6. When the appeal

Thavapriya, Tiruppur vs. ITO, Ward-2(1), Tiruppur

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

ITA 70/CHNY/2025[2019-20]Status: DisposedITAT Chennai15 Jul 2025AY 2019-20

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:70/Chny/2025 िनधा"रण वष" / Assessment Year: 2019-20 Thavapriya, Ito, Ward 2(1), 4/412, Aathal Thottam Road, Vs. Tirupur. Bharathi Nagar, Veerapandi Post, Tiruppur. [Pan:Awfpt-9644-N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. S.Sridhar, Advocate (Erode) By Virtual ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, J.C.I.T. सुनवाई की तारीख/Date Of Hearing : 02.06.2025 घोषणा की तारीख/Date Of Pronouncement : 15.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Shri. S.Sridhar, Advocate (Erode) by VirtualFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 1Section 142(1)Section 147Section 272A(1)(d)Section 273BSection 275

Therefore, the penalty levied under section 272A(1)(d) of the Act for non-compliance of notices was not warranted as there was a reasonable cause to the assessee as per the provisions of Section 273B of the Act. In light of the above, the ld.AR prayed for setting aside ... setting aside the order of the ld.CIT(A), holding that the assessee had shown the ‘reasonable cause’ as per section 273B of the Act. 9. In the result, appeal filed by the assessee is partly allowed. Order pronounced in the open court on 15th July, 2025 at Chennai. (मनु कुमार