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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

Raju Jhanghel, Raipur vs. Income Tax Officer-1(2), Raipur

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

ITA 446/RPR/2025[2015-16]Status: DisposedITAT Raipur05 Feb 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 445 & 446/Rpr/2025 (िनधा"रण वष" Assessment Years: 2014-15 & 2015-16) Raju Janghel, C/E Beside Trivenia Vs Income Tax Officer-1(2), Office Of Houshal Pan Thela, Gudhiyari, Ito-1(2), Cr Building, Civil Lines, Raipur, Chhattisgarh, 492001. Raipur, Chhattisgarh, 492001 Pan: Agrpj0572D (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Yogesh Kumar Sharma, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 03.02.2026 घोषणा की तारीख / Date Of : 05.02.2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri Yogesh Kumar Sharma, CIT-DR
Section 139Section 147Section 148Section 148ASection 250Section 68

Income Tax Officer-1(2), Raipur 8. The explanation of the Ld. AR therefore, becomes relevant to determine whether the same reflects sufficient and reasonable cause on his part in not presenting this appeal within the prescribed time. In case of Collector, Land Acquisition vs MST Katiji (Supra ... factual matrix of the present case, we Raju Janghel vs. Income Tax Officer-1(2), Raipur find that there exists sufficient and reasonable cause for condoning the delay in filing this appeal as held by the Hon’ble Supreme Court, where substantial justice and technical considerations are pitted against each

Raju Jhanghel, Raipur vs. Income Tax Officer-1(2), Raipur

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

ITA 445/RPR/2025[2014-15]Status: DisposedITAT Raipur05 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 445 & 446/Rpr/2025 (िनधा"रण वष" Assessment Years: 2014-15 & 2015-16) Raju Janghel, C/E Beside Trivenia Vs Income Tax Officer-1(2), Office Of Houshal Pan Thela, Gudhiyari, Ito-1(2), Cr Building, Civil Lines, Raipur, Chhattisgarh, 492001. Raipur, Chhattisgarh, 492001 Pan: Agrpj0572D (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Yogesh Kumar Sharma, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 03.02.2026 घोषणा की तारीख / Date Of : 05.02.2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri Yogesh Kumar Sharma, CIT-DR
Section 139Section 147Section 148Section 148ASection 250Section 68

Income Tax Officer-1(2), Raipur 8. The explanation of the Ld. AR therefore, becomes relevant to determine whether the same reflects sufficient and reasonable cause on his part in not presenting this appeal within the prescribed time. In case of Collector, Land Acquisition vs MST Katiji (Supra ... factual matrix of the present case, we Raju Janghel vs. Income Tax Officer-1(2), Raipur find that there exists sufficient and reasonable cause for condoning the delay in filing this appeal as held by the Hon’ble Supreme Court, where substantial justice and technical considerations are pitted against each

M/S. Buhari Holding Pvt. Ltd., Chennai vs. ACIT, CC-1(1), Chennai

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

ITA 2648/CHNY/2025[2018-19]Status: DisposedITAT Chennai05 Feb 2026AY 2018-19

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2648/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Buhari Holding Pvt. Ltd., The Assistant Commissioner No.5, Moores Road, Vs. Of Income Tax, Egmore, Central Circle -1(1), Chennai – 600 006. Chennai. Pan: Aaacb 2679M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 05.02.2026

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 143(1)Section 143(1)(a)

assessee had realized the necessity of filing of appeal only after receipt of consequential order of the CIT(A), it does not constitute a reasonable cause for the delay in filing the appeal. 4. We have heard rival submissions and perused the material on record. On mere perusal ... necessary action, who in turn advised filing appeal against the order passed by the CIT(A). It would, in our considered view constitute a reasonable cause for delay in filing the appeal. Accordingly, we condone the delay of 650 days in filing the appeal and admit the appeal for adjudication