← 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

Vineet Prakash Pol, Nashik vs. ACIT Circle-1, Nashik

In the result, appeal of the assessee is partly allowed

ITA 302/PUN/2025[2015-16]Status: DisposedITAT Pune26 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.302/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Vineet Prakash Pol, V The Acit, F-16, Midc, Ambad, S. Circle-1, Nashik. Nashik – 422010. Maharashtra. Pan: Abkpp4357J Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 26/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated31.01.2024For The A.Y.2015-16. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming The Disallowance Of Rs.13,81,195 Out Of The Total Disallowance Of Rs.30,74,834 Made By The A.O In Respect Of Interest Paid To Partnership Firms On Loans Obtained From Them Without Appreciating That The Said Disallowance Was Not Justified On Facts & In Law. 2. The Learned Cit(A) Ought To Have Appreciated That While

Section 250

filing appeal before ITAT. We have perused the Affidavit filed by the Assessee and are convinced that ITA No.302/PUN/2025[A] there is sufficient and reasonable cause for delay. Hence, the delay is condoned. 8. In the result, appeal of the assessee is partly allowed. Order pronounced in the open Court

Suvenjit Sen, Howrah vs. Income Tax Officer, Ward- 48(3), Kolkata

Appeals of the assessee are partly allowed

ITA 330/KOL/2025[2013-14]Status: DisposedITAT Kolkata26 May 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.329 & 330/Kol/2025 Assessment Years: 2012-13 & 2013-14 Suvenjit Sen……………….………….…………………………..….……….Appellant 3/1, N. C. Sen Lane, Salkia, Howrah-711106. [Pan: Ambps1594G] Vs. Ito, Ward-48(2), Kolkata……………....................……........……...…..…..Respondent Appearances By: Shri Anil Kochar, Ar Appeared On Behalf Of The Assessee. Shri Kallol Mistry, Jcit, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 13, 2025 Date Of Pronouncing The Order : May 26, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Two Separate Orders All Dated 26.06.2024 Passed By The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2012-13 & 2013-14 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. First, We Take Up The Issue In Respect Of Ita No.329/Kol/2025 For Assessment Year 2012-13. 2. At The Outset, The Registry Has Informed That There Are Delays Of 170 Days In Filing Both The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was

Section 144Section 250

filing both the present appeals. The assessee filed applications for condonation of delay stating reasons for such delay. After considering the applications, we find reasonable cause which was I.T.A. Nos.329 & 330/Kol/2025 Assessment Years: 2012-13 & 2013-14 Suvenjit Sen beyond the control of the assessee and the delays were

Suvenjit Sen, Howrah vs. Income Tax Officer, Ward- 48(2), Kolkata

Appeals of the assessee are partly allowed

ITA 329/KOL/2025[2012-13]Status: DisposedITAT Kolkata26 May 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.329 & 330/Kol/2025 Assessment Years: 2012-13 & 2013-14 Suvenjit Sen……………….………….…………………………..….……….Appellant 3/1, N. C. Sen Lane, Salkia, Howrah-711106. [Pan: Ambps1594G] Vs. Ito, Ward-48(2), Kolkata……………....................……........……...…..…..Respondent Appearances By: Shri Anil Kochar, Ar Appeared On Behalf Of The Assessee. Shri Kallol Mistry, Jcit, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 13, 2025 Date Of Pronouncing The Order : May 26, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Two Separate Orders All Dated 26.06.2024 Passed By The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2012-13 & 2013-14 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. First, We Take Up The Issue In Respect Of Ita No.329/Kol/2025 For Assessment Year 2012-13. 2. At The Outset, The Registry Has Informed That There Are Delays Of 170 Days In Filing Both The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was

Section 144Section 250

filing both the present appeals. The assessee filed applications for condonation of delay stating reasons for such delay. After considering the applications, we find reasonable cause which was I.T.A. Nos.329 & 330/Kol/2025 Assessment Years: 2012-13 & 2013-14 Suvenjit Sen beyond the control of the assessee and the delays were