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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

B H Trading Co, Delhi vs. DCIT, Central Circle-29, Delhi

In the result, the appeals of the assessee are partly allowed

ITA 519/DEL/2024[AY 2014-15]Status: DisposedITAT Delhi15 Oct 2024

Bench: Sh. Shamim Yahya & Sh. Sudhir Kumar

Section 142Section 142(1)Section 153CSection 271(1)(b)

requisite details and the documents in the compliance of the notices issued u/s. 142 (1) of the Act. The assessee has not shown any reasonable cause for non-compliance of the notices. The AO should have imposed the total penalty Rs.70,000/- instead of Rs.10,000/- for each notice

Meet Forex Private Limited, Delhi vs. ACIT(I&Ci), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2936/DEL/2022[2018-19]Status: DisposedITAT Delhi15 Oct 2024AY 2018-19

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year: 2018-19]

Section 2Section 271FSection 273BSection 285BSection 285B(1)

consultant to advice from time to time regarding compliance obligation, he held that the assessee was not able to show that there was reasonable cause within the meaning of section 273B of the I.T. Act for the delay in filing the SFT and thereby confirmed the penalty u/s 271FA

Smt. Devikaben Shailesh Chokshi L/H of Late Shailesh Ramanlal Chokshi, Ahmedabad vs. The Jt. CIT, Range-1(3), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 951/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R. N. Dsouza, CIT DR
Section 269SSection 271DSection 273B

above grounds of appeal, it ought to have been held that penalty is not validly levied as the appellant was prevented by a reasonable cause in terms of section 273B of the Act. The appellant craves leave to add, alter, amend any ground of appeal.” 4. Smt. Devikaben Shailesh Chokshi ... JCIT concluded that the circumstances warranted a penalty under Section 271D, and held that the appellant's acceptance of the gold loan without a reasonable cause constituted a violation of the provisions outlined in section 269SS of the Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT

Bhabar Bhabani Mandir Public Trust, West Bengal Burdwan vs. CIT Exemption, Kolkata

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

ITA 576/KOL/2024[2023-2024]Status: DisposedITAT Kolkata14 Oct 2024AY 2023-2024

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishrabhabar Bhabani Mandir Public Cit (Exemption), Kolkata, Trust, Income Tax Office, 10B, Kalna Saspur Kalna, Purba Vs Middleton Road, Bardhaman - 713409 Kolkata - 700071 (Pan: Aadtb5275B) (Appellant) (Respondent)

For Appellant: Kishan Agarwal, ARFor Respondent: Abhijit Kundu, CIT DR
Section 12ASection 8Section 80GSection 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)

there is no such provision nor there is any power to condone the delay after considering the reasonable reasons, a reasonable cause can be taken into cognizance for condoning the delay, if such provision is provided in the Act while considering any issue for adjudication. Therefore, considering the above proposition

Agarwal Sabha, Ulubari, Guwahati vs. CIT(Exemption), Kolkata

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

ITA 570/KOL/2024[2024-2025]Status: DisposedITAT Kolkata14 Oct 2024AY 2024-2025

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraagarwal Sabha, Cit (Exemption), Kolkata, H.No. 92A, Saratkunj 10B, Middleton Road, Apartment, Mill Road, Ulubari, Vs Kolkata - 700071 Guwahati (Pan: Aalaa5893M) (Appellant) (Respondent)

For Appellant: Ashok Kumar Agarwala, ARFor Respondent: Abhijit Kundu, CIT DR
Section 12ASection 80GSection 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)

there is no such provision nor there is any power to condone the delay after considering the reasonable reasons, a reasonable cause can be taken into cognizance for condoning the delay, if such provision is provided in the Act while considering any issue for adjudication. Therefore, considering the above proposition

Kishor Subhash Bane, Mumbai vs. Income Tax Officer, Ward 27(2)(1), Mumbai

In the result appeal filed by the assessee stands partly allowed

ITA 4199/MUM/2024[2015-16]Status: DisposedITAT Mumbai14 Oct 2024AY 2015-16

Bench: Smt. Beena Pillai, Jm & Smt. Renu Jauhri, Am

For Appellant: Shri K.Gopal &Shri AkhileshFor Respondent: Ms. Usha Gaikwad, Sr.DR
Section 143Section 249

both the years under consideration before the this Tribunal. 4. The Ld.AR submitted that, the assessee filed all relevant information to substantiate the reasonable cause in the delay in filing the appeals before the Ld.CIT(A), which was not considered. The Ld.AR thus prayed for the issues to be considered ... affidavits filed, along with the application seeking condonation of delay for the years under consideration. 5.2. In our view, the assessee made out reasonable cause for the delay caused in filing the appeals before the Ld.CIT(A). Nothing to establish anything contrary is filed by the revenue before this Tribunalby

Majidkhan Yakubkhan Pathan, Vadodara vs. The Income Tax Officer, Ward-3(1)(2), Vadodara

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

ITA 625/AHD/2024[2012-13]Status: HeardITAT Ahmedabad10 Oct 2024AY 2012-13

Bench: Dr. Brr Kumarasstt.Year : 2012-13 Majidkhan Yakubkhab Pathan Ito, Ward-3(1)(2) Basement Sardar Complex Vs Vadodara. Nr. Bank Of India Raopura, Vadodara Vadodara 390 001. Pan : Axlpp 0545 M (Applicant) (Responent) : Assessee By Shri P.F. Jain, Ar Revenue By : Shri Ravindra, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 10/10/2024 घोषणा क" तारीख /Date Of Pronouncement: 10/10/2024 आदेश/O R D E R आदेश आदेश आदेश

For Respondent: Shri Ravindra, SR.DR
Section 144Section 234ASection 250Section 68Section 69BSection 69C

occurred on account of lapse on the part of the tax consultant, which cannot be attributable to the assessee, and therefore, the assesse has reasonable cause for condonation of delay. Considering the submissions of the ld.counsel for the assessee and pleadings of the assessee in the condonation application ... view that the assessee has reasonable cause for the impugned delay, and desires to be condoned in the interest of justice. I do so, and take up the appeal of the assessee for adjudication. 4. At the outset, it is found that the order of the ld.CIT(A) does

Anil Joseph Reddy Thumma, Hyderabad vs. ITO., Ward-15(1), Hyderabad

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

ITA 768/HYD/2024[2018-19]Status: DisposedITAT Hyderabad10 Oct 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year – 2018-19 Anil Joseph Reddy Thumma Vs. Income Tax Officer Ward-15(1) Hyderabad Hyderabad Pan : Aezpt8652C (Appellant) (Respondent) Assessee By: Shri A.Harish, Ld.Ar Revenue By: Shri Madan Mohan Meena, Ld.Dr Date Of Hearing: 08.10.2024 Date Of Pronouncement: 10.10.2024

For Appellant: Shri A.Harish, Ld.ARFor Respondent: Shri Madan Mohan Meena, Ld.DR
Section 147Section 69Section 69A

sufficient sources for the deposits made in his bank account. Learned AR further submitted that the assessee is prevented by a reasonable cause for his inadvertent non-compliance before the revenue authorities. He, therefore, pleaded to afford an opportunity of being heard 3 before the learned CIT(A) to substantiate

Vanisri Mukta, Hyderabad vs. Income Tax Officer, Ward-9(1), Hyderabad

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

ITA 521/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Oct 2024AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year – 2017-18 Vanisri Mukta Vs. Income Tax Officer Ward-9(1) Hyderabad Hyderabad Pan : Amrpm7019G (Appellant) (Respondent) Assessee By: Shri K.C.Devdas, Ld.Ar Revenue By: Shri Madan Mohan Meena, Ld.Dr 08.10.2024 Date Of Hearing: Date Of Pronouncement: 10.10.2024

For Appellant: Shri K.C.Devdas, Ld.ARFor Respondent: Shri Madan Mohan Meena, Ld.DR
Section 1Section 148Section 156Section 271(1)(c)Section 69

admit the appeal for hearing. We have perused the affidavit filed by the assessee for condonation of delay and find that there is a reasonable cause for the assessee to file the appeal before the Tribunal with the delay of 70 days. We, therefore, condone the delay and admit

DCIT, Circle-2, Durgapur vs. Kalyan Educational Society, Kolkata

In the result, the appeal of the revenue is dismissed and the 18

ITA 1176/KOL/2023[2017-18]Status: DisposedITAT Kolkata10 Oct 2024AY 2017-18

Bench: Shri Rajpal Yadav & Dr. Manish Boradi.T.A. No.1176/Kol/2023 Assessment Year: 2017-18 Dcit, Circle-2, Durgapur ………. Appellant Vs. Kalyan Educational Society ………… Respondent 13, Dum Dum Cossipore Road, Dum Dum, Kolkata-700074. (Pan: Aabtk2860K) & C.O. No. 03/Kol/2024 In I.T.A. No.1176/Kol/2023 Assessment Year: 2017-18 Kalyan Educational Society ………… Cross Objector Vs. Dcit, Circle-2, Durgapur ……….. Respondent Appearances By: Shri Raja Sengupta, Addl. Cit, Sr. Dr Appeared For Revenue Shri S. K. Tulsiyan, Advocate & Ms. Puja Somani, Ca Appeared For Assessee/Cross Objector. Date Of Concluding The Hearing : 12.09.2024 Date Of Pronouncing The Order : 10.10.2024 Order Per Dr. Manish Borad: The Appeal Filed At The Instance Of The Revenue & The Cross Objection Filed At The Instance Of The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2017-18 Are Directed Against The Order Passed U/S 250 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Commissioner Of Income-Tax, (Appeals), National

Section 12ASection 133(6)Section 147Section 148Section 250Section 69A

before the bench to condone the said delay and admit the appeal for hearing. After hearing both the sides, we find that there is reasonable cause for late filing this appeal on behalf of the revenue, hence, we condone the delay and admit the appeal for hearing. 3. Grounds

Kasree Devi, Mawana Meerut vs. ITO Ward-1(1)(3), Ayakar Bhawan, Bhainsali Ground, Meerut

Appeal of the assessee is allowed

ITA 1019/DEL/2024[2017-2018]Status: DisposedITAT Delhi10 Oct 2024AY 2017-2018

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year: 2017-18

Section 115BSection 250Section 250(4)Section 69A

submissions as made in the application dated 5.3.2024 seeking condonation of delay. 3. Learned DR opposed the submissions and submitted that there is no reasonable cause for condoning the delay. 4. We have heard rival submissions and perused the material available on record. For the reasons stated in the condonation

The Hp State Co-Operative Marketing & Consumers Federation Limited, Shimla vs. DCIT, Circle, Shimla

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 155/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh09 Oct 2024AY 2017-18

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Balkrishan, ITPFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 14ASection 270ASection 270A(9)(a)Section 275Section 282

condonation application so filed by the assessee. It was submitted that there is a substantial delay in filing the present appeal and no reasonable cause has been shown in explaining the delay in filing the present appeal so filed by the assessee. 5. After hearing both the parties and considering

Shubhada Sanjay Sane, Maharashtra vs. Income Tax Officer, Ward Two (One) Kolhapur

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

ITA 1750/PUN/2024[2019-20]Status: DisposedITAT Pune09 Oct 2024AY 2019-20

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1750/Pun/2024 "नधा"रण वष" / Assessment Year : 2019-20 Shubhada Sanjay Sane, Vs. Ito, Ward-2(1), 413, D-Ward, Kolhapur Annapurna Apartment, Dravid Wada, Gangavesh-416002 Maharashtra Pan : Adxps8499K Appellant Respondent

For Appellant: NoneFor Respondent: Shri Harshad S. Aaradhi
Section 143(1)Section 154

delay for the period from the date of receipt of intimation, i.e. 16.11.2019 till 25.03.2020. In the absence of any 3 ‘sufficient and reasonable cause’ for delay, I am of the considered opinion that the Addl/JCIT(A) was justified in refusing to condone the delay. Even on merits, the Addl/JCIT

Nilesh Himmatrao Patil, Pune vs. ITO Ward 6(2), Pune

In the result, the appeal filed by the appellant trust stands partly allowed for statistical purposes

ITA 1586/PUN/2024[2012-13]Status: DisposedITAT Pune09 Oct 2024AY 2012-13

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1586/Pun/2024 "नधा"रण वष" / Assessment Year : 2012-13 Nilesh Himmatrao Patil, Vs. Ito, Ward-6(2), 301, Ujjwal Liberty, Pune Lane No.30/31, Ganesh Nagar, Dhayari B.O., Pune 411 041 Maharashtra Pan : Ardpp6570E Appellant Respondent

For Appellant: Shri Suhas P. BoraFor Respondent: Shri B.S. Rajpurohit
Section 133(6)Section 139(1)Section 142(1)Section 144Section 147Section 148Section 69A

appellant thereafter approached another Chartered Accountant who took 2 steps in filing the required details before the CIT(A)/NFAC. Thus, there was reasonable cause for not preferring the appeal within the stipulated time. 3. I have gone through the averments made in the affidavit filed by the appellant. There

Income Tax Officer, Kolkata vs. Mahacol Tie Up Pvt Ltd, Kolkata

In the result, the appeal of the Revenueis dismissed

ITA 1073/KOL/2024[2012-13]Status: DisposedITAT Kolkata09 Oct 2024AY 2012-13

Bench: the appellate proceedings, or in the course of appellate proceedings.”

Section 144Section 250

filed a petition praying for condonation of such delay. 4. We after perusing application filed by the revenue, find that there is a reasonable cause for the delay in filing the appeal by the revenue. Considering the same, condone such delay in filing the appeal by the revenue

Ceedeeyes It Parks Private Limited, Chennai vs. ITO Corporate Ward 1(3), Chennai

The appeal are dismissed

ITA 846/CHNY/2024[2018-19]Status: DisposedITAT Chennai09 Oct 2024AY 2018-19

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 846/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 M/S. Ceedeeyes It Parks Private Income Tax Officer, Limited, V. Corporate Ward -1(3), 42, Second Main Road, Gandhi Chennai. Nagar, Adyar, Chennai – 600 020. [Pan: Aaccc-3267-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. P. Hari Babu, Ca अपीलाथ"क"ओरसे/Appellant By ""यथ"क"ओरसे/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाईकीतारीख/Date Of Hearing : 27.08.2024 घोषणाकीतारीख/Date Of Pronouncement : 09.10.2024

For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(3)Section 37(1)

delay has been filed. After considering the petition 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

The City Club, Coimbatore vs. Income Tax Officer Ncw1(1), Coimbatore

The appeal stand allowed for statistical purposes

ITA 2007/CHNY/2024[2016-17]Status: DisposedITAT Chennai09 Oct 2024AY 2016-17

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2007/Chny/2024 (िनधा*रणवष* / Assessment Year: 2016-17) The City Club Ito बनाम/ 3, V.O.C Park Road, Non-Corporate Ward-1(1) Vs. Coimbatore-641 018. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabat-4005-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. Sandhyaarthi (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Ms. R. Anita (Addl.Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 24-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 09-10-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Ms. Sandhyaarthi (CA) - Ld.ARFor Respondent: Ms. R. Anita (Addl.CIT) - Ld. Sr. DR
Section 143(1)

appeal on merits which has been opposed by Ld. Sr. DR. 2. Though the assessee has remained negligent and could not establish reasonable cause for filing of first appeal with a delay, however, keeping in mind the principle of natural justice, we condone the delay before Ld. CIT(A) subject

Chinnasamy Ganesh Naidu Vijayavani, Krishnagiri vs. ITO, Ward-1, Hosur

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

ITA 1696/CHNY/2024[2015-16]Status: DisposedITAT Chennai09 Oct 2024AY 2015-16

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.1696/Chny/2024 िनधा"रण वष"/Assessment Year: 2015-16 V. Chinnasamy Ganesh Naidu- The Ito, Vijayavani, Ward-1, 169, Sipcot Housing Colony, Hosur. Mookandapally Dharga Hosur, Krishnagiri-635 126. [Pan: Ahfpv 9949 M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144

this appeal and assessee has filed condonation petition. Having Chinnasamy Ganesh Naidu Vijayavani :: 2 :: perused the same, we are satisfied that there is reasonable cause for delay. So, we condone the delay and proceed to adjudicate the appeal. 3. The main grievance of the assessee is against the action

Jeeta Ram, Faridabad vs. ITO Ward 1(3), Faridabad

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

ITA 1851/DEL/2024[2017-18]Status: DisposedITAT Delhi09 Oct 2024AY 2017-18

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Sanjay Tiwari, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 69A

severe health issue and family/professional difficulties. Hence, there is no ill intention of the Appellant in present case and there was a reasonable cause for the Appellant for no causing appearance on the date of fixed for hearing. 5. Income Tax demand imposed on the Appellant is not tenable ... department due to severe health issue and family / professional difficulties and therefore, there was no ill intention of the assessee and there was a reasonable cause for the assessee for non-appearance on the date of fixed for hearing. It was further submitted that the assessee was not provided

Kaushik Purshottamdas Sakaria, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(3)(Previously Ward-5(2)(5)), Ahmedabad

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

ITA 475/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad08 Oct 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

For Appellant: Shri Kushal Fofaria, ARFor Respondent: Smt. Bhavna Gupta Singh, Sr.DR
Section 250Section 69A

appellate stages was due to the medical Kaushik Purshottamdas Sakaria vs. ITO Asst. Year : 2017-18 condition of his CA, which is a reasonable cause for the non-submission of evidence at the earlier stages. 6.1. We are also of the view that the principles of natural justice require that