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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

Nanda Kishore Ravula, Hyderabad vs. ADIT (International Tax)-2, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 552/HYD/2025[2020-21]Status: DisposedITAT Hyderabad30 Jun 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.552/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2020-21) Nanda Kishore Ravula Vs. Adit (International Hyderabad Tax)-2 [Pan :Agupr0664F] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Nikhill Tiwari, Ar रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Dr सुिवधई की तधरीख/Date Of Hearing: 26/06/2025 घोर्णध की तधरीख/Date Of 30/06/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.01.2025 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2020-21. 2. The Brief Facts Of The Case Are That The Assessee, An Individual, Filed His Original Return Of Income For The A.Y.2020- 21 On 15.12.2020, Declaring Total Income Of Rs.1,08,11,550/-. Subsequently, The Assessee Filed Revised Return Of Income On 30.03.2021 & Claimed Foreign Tax Credit (“Ftc”) Of 2 Nanda Kishore Ravula

For Appellant: Shri Nikhill Tiwari, ARFor Respondent: Shri Gurpreet Singh, DR
Section 139(1)Section 139(5)Section 143(1)Section 143(3)Section 154Section 91

supra), was brought to the notice of the Bench, but looking at the abnormal delay of more than two years without any valid and reasonable cause, the Bench held that such delayed filing of Form 67 was in compliance with rule 128(9) of the Rules. 7. Coming

Mahabir S/O Sh Ram Niwas, Rohtak vs. Income Tax Officer Ward-1, Narnaul

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

ITA 1779/DEL/2025[2014-15]Status: DisposedITAT Delhi30 Jun 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwalmahabir Income Tax Officer, S/O Sh. Ram Niwas Nangal Ward, Narnaul. Kalia, Narnaul-123001 Vs. Pan:Cgkpm9657H (Appellant) (Respondent) Assessee By Ca Pranshu Singhal Department By Shri Narpat Singh, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac)-Delhi (‘The Cit(A) In Short) Dated 26.02.2024 In Appeal No. Nfac/2013-14/10168587 For Assessment Year 2014-15. 2. The Appeal Filed By The Assessee Is Delayed By 24 Days For Which An Affidavit Along With Condonation Petition Was Filed By The Assessee Wherein It Is Stated That Email-Id Provided In Form No.35 Was Different & The Notices Sent By The Ld. Cit(A) Were On Different Email-Id, Therefore, The Notices For Hearing Could Not Be Served Upon The Assessee. Therefore, Neither The Assessee Could Be Able To Appear Before Ld. Cit(A) Nor Have Any Knowledge About The Passing Of The Order By Ld. Cit(A). When The Assessee Received Notice For Pending Penalty Proceedings, He Contacted With Its Counsel Who Intimated About The Appellate Prodder. Under These Facts & Circumstances, It Is Requested That The Delay In Filing The Appeal Be Condoned & Appeal Be Admitted For Adjudication.

Section 147

parties. From the perusal of the affidavit filed by the assessee and the reasons stated therein, we find that there is sufficient and reasonable cause with the assessee where the assessee was not intimated on the correct email-id about the passing of the order and, therefore, the appeal could

Shree Rama Rajya Parishad, Palwal Faridabad vs. Income Tax Offficer, Faridabad

In the result, both the appeals of the assesse are partly allowed

ITA 5704/DEL/2024[NA]Status: DisposedITAT Delhi30 Jun 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita No.5704/Del/2024 (Assessment Year: -----) Shree Rama Rajya Parishad, Commissioner Of Income Near Prem Dairy, Tax (Exemption), By Pass Road, Vs. Chandigarh New Colony, Palwal, Haryana-121101 Pan:Dnqpd2476F (Appellant) (Respondent) Assessee By Ca Raaj Kumar Sohanpal Rawat Department By Shri N.K. Bansal, Cit- Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Exemptions), Chandigarh (‘The Cit(E) In Short), Dated 06.08.2024 Rejecting The Application For Registration U/S 12A & 80G Of The Act. As Both The Appeals Are Related To Issue Of Registration U/S 12A & 80G, Thus They Are Decided By A Common Order. 2. The Appeal Filed By The Assessee Is Delayed By 39 Days For Which An Affidavit Along With Condonation Petition Was Filed By Theof The Assessee Society Namely Ms. Santushti Thapar Wherein It Is Stated That It Had Engaged One Ca Pooja Sharma To Represent & File The Necessary Details Before The Ld. Cit(E). However, Due To Her Pregnancy, She Could Not Be Able To File The Appeals Within Time. Under These Facts & Circumstances, It Is Requested That The Delay In Filing The Appeal Be Condoned & Both The Appeals Be Admitted For Adjudication. Reliance Is Also Placed On The Judgement Of 2 It Nos.5703 & 5704/Del/2024 Shree Rama Rajaya Parishad Vs. Cit Hon’Ble Supreme Court In The Case Of Collector, Land Acquisition Vs. Mst. Katiji (1987) 167 Itr 471 (Sc).

Section 12A

parties. From the perusal of the affidavit filed by the assessee and the reasons stated therein, we find that there is sufficient and reasonable cause with the assessee for filing the appeal with in prescribed time limit. It must be remembered that in every case of delay there

Shree Rama Rajya Parishad, Palwal Haryana vs. Income Tax Officer, Faridabad

In the result, both the appeals of the assesse are partly allowed

ITA 5703/DEL/2024[NA]Status: DisposedITAT Delhi30 Jun 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita No.5704/Del/2024 (Assessment Year: -----) Shree Rama Rajya Parishad, Commissioner Of Income Near Prem Dairy, Tax (Exemption), By Pass Road, Vs. Chandigarh New Colony, Palwal, Haryana-121101 Pan:Dnqpd2476F (Appellant) (Respondent) Assessee By Ca Raaj Kumar Sohanpal Rawat Department By Shri N.K. Bansal, Cit- Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 O R D E R Per Manish Agarwal, Am: These Two Appeals Are Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Exemptions), Chandigarh (‘The Cit(E) In Short), Dated 06.08.2024 Rejecting The Application For Registration U/S 12A & 80G Of The Act. As Both The Appeals Are Related To Issue Of Registration U/S 12A & 80G, Thus They Are Decided By A Common Order. 2. The Appeal Filed By The Assessee Is Delayed By 39 Days For Which An Affidavit Along With Condonation Petition Was Filed By Theof The Assessee Society Namely Ms. Santushti Thapar Wherein It Is Stated That It Had Engaged One Ca Pooja Sharma To Represent & File The Necessary Details Before The Ld. Cit(E). However, Due To Her Pregnancy, She Could Not Be Able To File The Appeals Within Time. Under These Facts & Circumstances, It Is Requested That The Delay In Filing The Appeal Be Condoned & Both The Appeals Be Admitted For Adjudication. Reliance Is Also Placed On The Judgement Of 2 It Nos.5703 & 5704/Del/2024 Shree Rama Rajaya Parishad Vs. Cit Hon’Ble Supreme Court In The Case Of Collector, Land Acquisition Vs. Mst. Katiji (1987) 167 Itr 471 (Sc).

Section 12A

parties. From the perusal of the affidavit filed by the assessee and the reasons stated therein, we find that there is sufficient and reasonable cause with the assessee for filing the appeal with in prescribed time limit. It must be remembered that in every case of delay there