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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

Rajesh B, Jain As Legal of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

ITA 1938/MUM/2024[2008-09]Status: DisposedITAT Mumbai29 Jan 2026AY 2008-09

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am Ι.Τ.Α. No.1938/Mum/2024 (Assessment Year: 2008-09) Ι.Τ.Α. No.1937/Mum/2024 (Assessment Year: 2009-10) Ι.Τ.Α. No.1940/Mum/2024 (Assessment Year: 2010-11) Ι.Τ.Α. No.1939/Mum/2024 (Assessment Year: 2011-12) Ι.Τ.Α. No.1941/Mum/2024 (Assessment Year: 2012-13) Ι.Τ.Α. No.1942/Mum/2024 (Assessment Year: 2013-14) Ι.Τ.Α. No.1936/Mum/2024 (Assessment Year: 2014-15) Rajesh B. Jain As Legal Heir Of Bhanwarlal Jain, 171, 17Th Floor, Silver Arch, Petit Hall Compound, Nepeansea Road, Mumbai - 400006 Pan: Aafpj1924R Assessee -अपीलार्थी / Appellant Vs. Ito, Ward-19(1)(1), Piramal Chamber, Lalbaug, Mumbai-400012. Revenue - प्रत्यर्थी / Respondent : Assessee By : Shri Madhur Agarwal, Adv, Shri Fenil Bhat & Shri Sucheck Anchaliya, Ca

For Appellant: Shri Madhur Agarwal, AdvFor Respondent: Assessee by
Section 143(1)Section 271Section 271(1)(c)

specific reason or details of any mitigating circumstances due to which the non compliance occurred. Accordingly, I find that the assessee had no reasonable cause for committing the default of not furnishing correct particulars and thereby concealing her income. In the case of CIT v. Standard Mercantile ... held that it was for the assessee to show that he had reasonable cause for not complying with the provisions of the Act. It has also been laid down by the Hon'ble Supreme Court in a judgment reported in (1987) 165 ITR 14, 21-22 that the initial burden

Uttarakhand Vikas Samiti, Udaipur vs. DCIT, CPC / ITO, Ward Exemption, Udaipur

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

ITA 257/JODH/2025[2018-19]Status: DisposedITAT Jodhpur28 Jan 2026AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Bleuttarakhand Vikas Samiti Vs. Dcit, Cpc/Ito, Ward Exemption, 117, Main Road, Bhupalpura, Udaipur - 313001 Udaipur - 313001 Pan No. Aaatu 3935 G Assessee By Shri Yogesh Pokharna, C.A. (Physical) Shri K.C. Meena, Addl. Cit-Dr (Virtual) Revenue By Date Of Hearing 13.01.2026. Date Of Pronouncement 28.01.2026. Order Dr. Mitha Lal Meena, A.M.: The Appeal By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax, Appeal, Addl/Jcit (A) Patna [Hereinafter Referred To As “The Jcit Appeal”] Dated 24.01.2025 With Respect To Assessment Year 2018-19 Challenging Therein Confirmation Of Addition Of Rs. 6,00,000/- Without Appreciating Facts Of The Case.

Section 10BSection 11Section 119(2)Section 119(2)(b)Section 12ASection 143(1)Section 8

Commissioner of Income Tax, while interpreting such belated applications in form 9A and form no. 10 satisfied this that the assessee was apprehended by reasonable cause from filing of applications in form no. 9A and form no. 10 within the stipulated time. Further, with respect of form ... Commissioners will, while entertaining such belated applications in Form No. 9A and Form No. 10, satisfy themselves that the assessee was prevented by reasonable cause from filing of applications in Form No. 9A and Form No. 10 within the stipulated time. Further, in respect of Form No. 10 the Commissioners

Raisoni Bagrecha Diamonds Private Limited, Jalgaon vs. Pne-C-(25)(1), Circle 1, Jalgaon

In the result, appeals of the assessee’s are allowed for statistical purposes

ITA 2549/PUN/2025[2017-2018]Status: DisposedITAT Pune28 Jan 2026AY 2017-2018

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No.1971/Pun/2025 धििाारण वर्ा /Assessment Year: 2015-16 R.B. Diamond House, Pne-C-1, Range-25, Opposite Manohar Sarees Circle-1, Jalgaon Baliram Peth, Jalgaon- Vs. 425001 Maharashtra Pan-Aaifr9130Q अपीलार्थी / Appellant प्रत्यर्थी/Respondent आयकर अपील सं./Ita No. 2549/Pun/2025 धििाारण वर्ा /Assessment Year: 2017-18 Raisoni Bagrecha Diamonds Pne-C-(25)(1), Circle- Private Limited, 1, Jalgaon 288, Baliram Peth, Jalgaon- Vs. 425001 Maharashtra Pan-Aadcr7439N अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Sanjay T. Tupe Department By: Shri R.Y. Balawade, Addl. Cit Date Of Hearing: 28-01-2026 Date Of Pronouncement: 30-01-2026 आदेश / Order Per Dr. Manish Borad:- The Captioned Appeals By Two Different Assessee’S Are Directed Against The Order Passed U/S 250 Of The Income-Tax Act, 1961 Dated 10.06.2025 & 14.08.2025 Pertaining To A.Y.

For Appellant: Shri Sanjay T. TupeFor Respondent: Shri R.Y. Balawade, Addl. CIT
Section 147Section 250Section 250(6)Section 272A(1)(d)

latest e-mail id and mobile No. on the website and also remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee’s are allowed for statistical purposes. 3 & 4. In the result, appeals of the assessee

R B Diamond House, Jalgaon vs. Pne-C-1, Range -25, Circle -1, Jalgaon

In the result, appeals of the assessee’s are allowed for statistical purposes

ITA 1971/PUN/2025[2015-16]Status: DisposedITAT Pune28 Jan 2026AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No.1971/Pun/2025 धििाारण वर्ा /Assessment Year: 2015-16 R.B. Diamond House, Pne-C-1, Range-25, Opposite Manohar Sarees Circle-1, Jalgaon Baliram Peth, Jalgaon- Vs. 425001 Maharashtra Pan-Aaifr9130Q अपीलार्थी / Appellant प्रत्यर्थी/Respondent आयकर अपील सं./Ita No. 2549/Pun/2025 धििाारण वर्ा /Assessment Year: 2017-18 Raisoni Bagrecha Diamonds Pne-C-(25)(1), Circle- Private Limited, 1, Jalgaon 288, Baliram Peth, Jalgaon- Vs. 425001 Maharashtra Pan-Aadcr7439N अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Sanjay T. Tupe Department By: Shri R.Y. Balawade, Addl. Cit Date Of Hearing: 28-01-2026 Date Of Pronouncement: 30-01-2026 आदेश / Order Per Dr. Manish Borad:- The Captioned Appeals By Two Different Assessee’S Are Directed Against The Order Passed U/S 250 Of The Income-Tax Act, 1961 Dated 10.06.2025 & 14.08.2025 Pertaining To A.Y.

For Appellant: Shri Sanjay T. TupeFor Respondent: Shri R.Y. Balawade, Addl. CIT
Section 147Section 250Section 250(6)Section 272A(1)(d)

latest e-mail id and mobile No. on the website and also remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee’s are allowed for statistical purposes. 3 & 4. In the result, appeals of the assessee