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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

Late Nammalvar, Rep. by Padma Nammalvar, Nannilam vs. ITO, Ward-1, Tiruvarur

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

ITA 2310/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Jan 2026AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2310/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Late Nammalvar, The Income Tax Officer, Rep. By Smt. Padma Vs. Ward 1, Nammallvar, Tiruvarur No.1, Andal Gas Agency, Tiruvarur Main Road, Nannilam – 610 105. Pan: Aaepn 6229J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Girish Kumar, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Rajakumar, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 28.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 30.01.2026

For Appellant: Shri S. Girish Kumar, AdvocateFor Respondent: Shri N. Rajakumar, Addl.CIT
Section 139Section 250Section 271BSection 273BSection 44A

audit report. In this context, it was submitted that the delay in filing the audit :- 3 -: report may be condoned as there is reasonable cause as mandated u/s.273B of the Act. However, the contentions raised by the assessee during the course of penalty proceedings were rejected and penalty u/s.271B ... familiar with the business and then filed the return of income and audit report. On the facts of the instant case, there is reasonable cause as mandated u/s.273B of the Act for belated filing of audit report u/s.44AB of the Act. Hence, we delete the penalty imposed u/s.271B

Mercy Education Trust, Chennai vs. ITO, Ncw-19(6), Chennai

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

ITA 2231/CHNY/2025[2018-19]Status: DisposedITAT Chennai29 Jan 2026AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2231/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mercy Education Trust, The Income Tax Officer, No.66, Sree Gokulam Towers, Vs. Non-Corporate Ward 19(6), Arcot Road, Chennai. Kodambakkam, Chennai – 600 024. Pan: Aactm 6190M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Rajakumar, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 29.01.2026

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri N. Rajakumar, Addl.CIT
Section 10Section 139Section 147Section 148Section 250Section 272A(2)(e)Section 273B

NFAC, Delhi failed to appreciate that in any event, the present penal provisions under consideration should be subjected to reasonable cause in terms of Section 273B of the Act and further ought to have appreciated that the discretion vested with the Assessing Officer for passing/not passing the penalty order ... however rejected the contentions of the assessee. The FAA held that :- 6 -: ignorance of assessee of statutory filing of return is not a reasonable cause as mandated u/s.273B of the Act and confirmed the penalty imposed u/s.272A(2)(e) of the Act. 6. Aggrieved by the order of FAA, assessee