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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

Jayeshkumar Harjani, Panchmahal vs. The ITO, Ward-4(1)(2), Vadodara

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

ITA 2072/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad11 Apr 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No. 2072/Ahd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Jayeshkumar Harjani Prop. Of J. P. Enterprise, Municipal Shopping Centre, V/S. B/H. New Bus Stand, At. Po. Godhra, Dist. Panchmahal, Godhra, Gujarat – 389001 Income Tax Officer बनाम/ Ward- 4(1)(2), Vadodara स्थायी लेखा सं./Pan: Acoph2412D अपीलार्थी/ (Appellant) प्रत्यर्थी/ (Respondent) Assessee By: Shri Sunil Maloo, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 09/04/2025 घोषणा की तारीख /Date Of Pronouncement: 11/04/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 08.10.2024 Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)"], For The Assessment Year 2017-18, Whereby The Ld. Cit(A) Dismissed The Appeal Filed By The Assessee In Limine On The Ground Of Delay.

For Appellant: Shri Sunil Maloo, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 143(3)Section 249(2)(c)Section 68Section 69C

dismissing assessee's appeal without considering the merits of case merely for delay of 17 days in filing of appeal due to sufficient reasonable cause.” 5. During the course of hearing before us, the Ld. Authorised Representative (AR) submitted that the assessee is a small taxpayer and was not fully

Maharashtra Cricket Association, Pune vs. ACIT(E), Pune

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

ITA 975/PUN/2024[2012-13]Status: DisposedITAT Pune11 Apr 2025AY 2012-13

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1387 & 975/Pun/2024 धििाारण वर्ा / Assessment Years : 2011-12 & 2012-13 Maharashtra Cricket Association, Acit(E), Pune Gahunje Stadium, At Post Gahunje, Thehsil-Maval, Pune-412101 Vs. Pan : Aaatm2192D अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri C.H. Naniwadekar & Kiran Sanmane Department By : Shri Amol Khairnar Date Of Hearing : 16-01-2025 Date Of 11-04-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : Two Appeals Filed By The Assessee Are Directed Against The Two Separate Orders Dated 22.04.2024 & 12.03.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”] Pertaining To Assessment Years (“Ays”) 2011-12 & 2012-13. Since The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri C.H. Naniwadekar &For Respondent: Shri Amol Khairnar
Section 11Section 2(15)

further submissions before the Ld. CIT(A) to substantiate its case on the appointed date without seeking any adjournment unless otherwise required for the reasonable cause failing which the Ld. CIT(A) shall be at liberty to pass appropriate order as per law. All the grounds

Maharashtra Cricket Association, Pune vs. ACIT(E), Pune

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

ITA 1387/PUN/2024[2011-12]Status: DisposedITAT Pune11 Apr 2025AY 2011-12

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1387 & 975/Pun/2024 धििाारण वर्ा / Assessment Years : 2011-12 & 2012-13 Maharashtra Cricket Association, Acit(E), Pune Gahunje Stadium, At Post Gahunje, Thehsil-Maval, Pune-412101 Vs. Pan : Aaatm2192D अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri C.H. Naniwadekar & Kiran Sanmane Department By : Shri Amol Khairnar Date Of Hearing : 16-01-2025 Date Of 11-04-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : Two Appeals Filed By The Assessee Are Directed Against The Two Separate Orders Dated 22.04.2024 & 12.03.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”] Pertaining To Assessment Years (“Ays”) 2011-12 & 2012-13. Since The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri C.H. Naniwadekar &For Respondent: Shri Amol Khairnar
Section 11Section 2(15)

further submissions before the Ld. CIT(A) to substantiate its case on the appointed date without seeking any adjournment unless otherwise required for the reasonable cause failing which the Ld. CIT(A) shall be at liberty to pass appropriate order as per law. All the grounds