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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

Smiles Foundation, Satara vs. CIT Exemption Pune, Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1113/PUN/2025[2024-25]Status: DisposedITAT Pune16 Jun 2025AY 2024-25

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1113/Pun/2025 Smiles Foundation, V The Cit Exemption, Shop No.2, 1671/A 170 Sushila S. Pune. Vasant Vihar, Mangalwar Peth, Satara – 415002. Maharashtra. Pan: Aasts2069K Appellant/ Assessee Respondent / Revenue Assessee By Shri Praful S. Shaha – Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 12/06/2025 Date Of Pronouncement 16/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Dated 08.08.2024 Rejecting Assessee’S Application For Registration Under Section 80G(5) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : “1. Clarification On Loan From Trustees: We Would Like To Appeal That The Loan Was Taken Interest Free From The Trustee. The Intention Was To Just Carry On The Activities Of The Trust Without Any Intention To Gain Benefit. Hence We Request You To Consider This Fact. Also The Appellant Has Made Significant Efforts To Follow Legal Requirements & Requests That This Matter Be Reconsidered.

Section 12Section 12ASection 80G(5)

days. Assessee has filed an Affidavit of the Trustee. We have perused the Affidavit and we found the there is sufficient and reasonable cause for Delay, therefore, the delay is condoned. Findings & Analysis : 2. We have heard both the parties and perused the records. Mr.Praful Suresh Shaha

Sellappa Gounder Kuppusamy, Tiruppur vs. ITO, Ward-2(4), Tiruppur

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

ITA 793/CHNY/2025[2011-12]Status: DisposedITAT Chennai16 Jun 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.793/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Sellappa Gounder Kuppusamy, Vs. The Income Tax Officer, 125, Sulliporukkupalaiyam, Ward 2(5), Kilangundal, Mulanur, Tiruppur. Tiruppur 638 106. [Pan:Bbdpk7658F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Muthu Kumar, C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 16.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2011-12. 2. The Assessee Raised 2 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Rejecting The Condonation Petition & Confirming The Addition Made By The Assessing Officer When The Assessee Has Opted For 2

For Appellant: Shri K. Muthu Kumar, C.AFor Respondent: Ms. R. Anita, Addl. CIT
Section 143(2)Section 144Section 148Section 44ASection 69A

been under medical treatment from 10.09.2018 to 15.07.2019. Under the above facts and circumstances, we find that the assessee was prevented by reasonable cause for the delay in filing appeal before the ld. CIT(A) subject to the condition of payment of ₹.10,000/- in favour of the State Legal