← 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

Income Tax Officer Ward Hingoli Camp at Parbhani, Parbhani vs. Rajaram Ramswarup Jaju, Selu Parbhani

In the result, the cross objection filed by the assessee in C

ITA 1882/PUN/2024[2016-17]Status: DisposedITAT Pune07 Mar 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1882/Pun/2024 िनधा"रण वष" / Assessment Year : 2016-17 Ito, Ward Hingoli Camp At Vs. Rajaram Ramswarup Parbhani, Parbhani. Jaju, 223, Jaju Industries Atre Nagar, Selu, Parbhani- 431503. Pan : Aakpj4951H Appellant Respondent C.O. No.35//Pun/2024 (Arising Out Of Ita No.1882/Pun/2024) िनधा"रण वष" / Assessment Year : 2016-17 Rajaram Ramswarup Jaju, Vs. Ito, Ward Hingoli 223, Jaju Industries Atre Camp At Parbhani, Nagar, Selu, Parbhani. Parbhani- 431503. Pan : Aakpj4951H Appellant Respondent Revenue By : Shri Basavaraj Hiremath Assessee By : Shri Anand R. Partani & Shri Darshan R. Gattani Date Of Hearing : 09.12.2024 Date Of Pronouncement : 07.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 15.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment

For Appellant: Shri Anand R. Partani &For Respondent: Shri Basavaraj Hiremath
Section 142(1)Section 147Section 148Section 69A

with the reasons mentioned in the application for condonation of delay and we are of the considered opinion that the assessee was prevented by reasonable cause in not filing the cross objection within the time limit prescribed by the Statute. Accordingly, we condone the delay of 61 days and admit

Thenmaipakkam Primary Agricultural Co-Op Bank Ltd., Kancheepuram vs. It, Ncc-22(1), Tambaram

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

ITA 2899/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Mar 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं/.Ita No.: 2899/Chny/2024 यनिाारण िर्ा / Assessment Year: 2019-20 Thenmelpakkam Perimary The Income Tax Officer, Agricultural Cooperative Bank V. Non-Corp Circle-22(1), Limited, Thenmelpakkam Village Tambaram. Anjur Post, Kancheepuram, Tamil Nadu – 603 204. [Pan: Aacat7857-R] अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. G.Akash, Advocate प्रत्यथी की ओर से/Respondent By : Dr. M.D. Vijay Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 05.03.2025 घोषणा की तारीख/Date Of Pronouncement : 07.03.2025 आदेश/ O R D E R Per S. R. Raghunatha: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), Addl/Jcit(A)-1, Gurugram, Dated 28.06.2024 & Pertains To Assessment Year 2023-24. 2. At The Outset, We Find That There Is A Delay Of 75 Days In Appeal Filed By The Assessee, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition

For Appellant: Shri. G.Akash, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 139(1)Section 80ASection 80P

After considering the petition :-2-: ITA. No: 2899/Chny/2024 filed by the assessee and also hearing both the parties, we find that there is a reasonable cause for the assessee in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice

Sahayog Charitable Trust, Nashik vs. CIT(E), Pune

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

ITA 2871/PUN/2024[2025-26]Status: DisposedITAT Pune06 Mar 2025AY 2025-26

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2871/Pun/2024 Sahayog Charitable Trust, Vs. Cit, Exemption, Pune. Ramashree Plot No.10, Near Trikoni Garden, Swarka Kathe Galli, Nashik- 422011. Pan : Aabts8420M Appellant Respondent Assessee By : Shri Sanket M. Joshi (Virtual) Revenue By : Shri Ajay Kumar Keshari Date Of Hearing 05.03.2025 : Date Of Pronouncement 06.03.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 08.11.2024 Passed By Ld. Cit, Exemption, Pune Rejecting The Application For Registration U/S 80G Of The It Act. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Learned Cit(E) Erred In Rejecting Application Filed By The Appellant In Form 10Ab For Approval Under Sub Clause (Iii) Of First Proviso To Section 80G(5) Without Appreciating That The Said Action Was Not Justified On Facts & In Law. 2. The Appellant Submits That There Was A Reasonable Cause Due To Which Notice Dated 1.10.2024 Issued By Cit(E), Pune Could Not Be Complied & Hence, It Is Prayed That In The Interest Of Justice, The Matter May Please Be Restored To The File Of Cit(E), Pune To Adjudicated The Same On Merits After Granting One More Opportunity Of Being Heard. 3. The Appellant Craves Leave To Add/ Alter/ Amend Any Of The Grounds Of Appeal.”

For Appellant: Shri Sanket M. Joshi (Virtual)For Respondent: Shri Ajay Kumar Keshari
Section 80GSection 80G(5)

without appreciating that the said action was not justified on facts and in law. 2. The appellant submits that there was a reasonable cause due to which notice dated 1.10.2024 issued by CIT(E), Pune could not be complied and hence, it is prayed that in the interest of justice