← All Phrases

“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

Planex Projects and Constructions Private Limited, Ernakulam vs. Commissioner of Income Tax, Kozhikode

In the result, the appeal filed by the assessee stands dismissed

ITA 844/COCH/2024[2019-2020]Status: DisposedITAT Cochin27 Jun 2025AY 2019-2020

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2019-20 Planex Projects & Constructions Pvt. Ltd. .......... Appellant No. Xxv/4, Kerala State Houseing Building Changampuzha Nagar,South Kalamassery 682 [Pan: Aagcp3634A] Vs. The Income Tax Officer .......... Respondent Ward-1(1) & Tps, Kozhikode Appellant By: Smt. Parvathy Ammal, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 21.05.2025 Date Of Pronouncement: 27.06.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-2, Surat [Cit(A)] Dated 10.07.2024 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is A Company Engaged In The Business Of Execution Of Civil Contracts. The Return Of Income For Ay 2019-20 Was Filed On 30.10.2019 Declaring Nil Income. The Same Was Revised On 06.06.2020 At Nil Income. The 2 Planex Projects & Constructions Pvt. Ltd. Said Return Of Income Was Processed By The Cpc U/S. 143(1) Of The Income Tax Act, 1961 (The Act) Vide Intimation Dated 22.09.2020 After Making Adjustment Of Unpaid Gst Of Rs. 67,54,054/-.

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(1)Section 43B

admitted for adjudication. On a perusal of the averments made in the condonation petition, it is evident that the appellant is prevented by reasonable cause from filing the appeal. Therefore, we condone the delay and admit the appeal for adjudication. 6. The learned counsel for the assessee submits that

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 274/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

held that the assessee has contravened the provisions of Section 269T of the Income Tax Act, 1961. Further, the assessee has not cited any reasonable cause for violation of the provisions of section 269T of the Act. In view of these facts, it is a case where the assessee, without ... reasonable cause, has contravened the provisions of section 269T of the Act. Therefore, ld. AO hold that the assessee has violated the provisions of section 269T of the Act, which puts an embargo on re-payment of loans except by the modes specified therein and, therefore, penalty u/s 271E

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 271/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

held that the assessee has contravened the provisions of Section 269T of the Income Tax Act, 1961. Further, the assessee has not cited any reasonable cause for violation of the provisions of section 269T of the Act. In view of these facts, it is a case where the assessee, without ... reasonable cause, has contravened the provisions of section 269T of the Act. Therefore, ld. AO hold that the assessee has violated the provisions of section 269T of the Act, which puts an embargo on re-payment of loans except by the modes specified therein and, therefore, penalty u/s 271E

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 268/JPR/2025[2013-14]Status: DisposedITAT Jaipur26 Jun 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं./ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Kiran Fine Jewellers Private Tax, Vs. Limited Central Circle-02, Jaipur F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Shri R. K. Bhatra, CA राजस्व की

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

held that the assessee has contravened the provisions of Section 269T of the Income Tax Act, 1961. Further, the assessee has not cited any reasonable cause for violation of the provisions of section 269T of the Act. In view of these facts, it is a case where the assessee, without ... reasonable cause, has contravened the provisions of section 269T of the Act. Therefore, ld. AO hold that the assessee has violated the provisions of section 269T of the Act, which puts an embargo on re-payment of loans except by the modes specified therein and, therefore, penalty u/s 271E