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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

Kamini Velmurugan, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 478/MUM/2026[2016-17]Status: DisposedITAT Mumbai17 Mar 2026AY 2016-17

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2016-17 Kamini Velmurugan, Income Tax Officer, 18/369, Rajeshwari Chs, Ward-42(2)(3), Subhasnagar, Vs. Kautilya Bhavan, Mumbai-400071. Mumbai-400051. Pan : Agzpn9256A (Appellant) (Respondent) For Assessee : Ms. Sailee Gujarathi For Revenue : Shri Aditya Rai, Sr.Dr Date Of Hearing : 04-03-2026 Date Of Pronouncement : 17-03-2026 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 19-11-2025, Pertaining To Assessment Year (Ay) 2016-17. 2. Briefly, The Facts Of The Case Are That The Assessment In This Case Was Completed U/S. 147 R.W.S. 144 R.W.S. 144B Of The Income Tax Act, 1961 („The Act‟), Vide Order Dt. 12-12-2023, Wherein The Ao Has Brought To Tax A Sum Of Rs. 42,50,000/- As Short Term Capital Gains U/S. 45 Of The Act In Absence Of Any Explanation/Evidences Submitted By The Assessee In Respect Of Sale Of Immoveable Property As Well As Cost Of Acquisition. The 2 Assessee Thereafter Carried The Matter In Appeal Before The Ld.Cit(A), Who Has Since Dismissed The Appeal On Account Of Delayed Filing & Against The Said Order, The Assessee Is In Appeal Before Us.

For Appellant: Ms. Sailee GujarathiFor Respondent: Shri Aditya Rai, Sr.DR
Section 147Section 45Section 45(1)

lower authorities. 8. We have heard the rival contentions and perused the material available on record. Firstly, we find that there was a reasonable cause for the delay in filing the appeal before the Ld.CIT(A). The contents of the affidavit filed by the assessee have not been rebutted

Sanjay Shamrao Sawant, Navi Mumbai vs. Income Tax Officer, Ward 42(3)(3), Mumbai

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

ITA 469/MUM/2026[2016-17]Status: DisposedITAT Mumbai17 Mar 2026AY 2016-17

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2016-17 Sanjay Shamrao Sawant, Income Tax Officer, Flat No. B-3/701, 7Th Floor, Ward-35(3)(1), [Presently – Ito, Ward-42(3)(3)] Millenium Towers, Vs. Mumbai. Near Ryan School, Sector-9, Sanpada, Navi Mumbai-400705. Pan : Bdyps3261H (Appellant) (Respondent) For Assessee : None For Revenue : Shri Aditya Rai, Sr.Dr Date Of Hearing : 04-03-2026 Date Of Pronouncement : 17-03-2026 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Addl/Jcit(A)-Kochi [„Ld.Cit(A)‟], Dated 18-09-2025, Pertaining To Assessment Year (Ay) 2016-17. 2. None Appeared On Behalf Of The Assessee Nor Was Any Adjournment Application Filed. However, Considering The Matter, We Find That No Useful Purpose Would Be Served In Adjourning The Matter Any Further & To Decide The Matter Based On Material Available On Record.

For Appellant: NONEFor Respondent: Shri Aditya Rai, Sr.DR
Section 143(3)Section 69Section 69A

pointed out by the Registry. After pursuing the affidavit submitted by the assessee and hearing the ld DR, we find that there was reasonable cause for the delay in filing the present appeal and hence, the delay is hereby condoned and appeal is admitted for adjudication. 4. Briefly, the facts