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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

Assistant Commissioner of Income Tax, Circle-3.3.1, Mumbai vs. Shapoorji Pallonji Solar Holdings Pvt. Ltd., Mumbai

In the result, the appeal is dismissed

ITA 5135/MUM/2024[2021-22]Status: DisposedITAT Mumbai23 Jan 2026AY 2021-22

Bench: Shri Saktijit Dey & Shri Jagadishasst. Cit, Circle 3.3.1 Shapoorji Pallonji Solar Holdings Room No. 522, 5Th Floor, Pvt. Ltd. Aayakar Bhavan, M. K. Road, Vs. 41/44, Sp. Centre Minoo Desai Mumbai-400 020 Marg, Colaba, Mumbai-400 005 Pan/Gir No. Aagcp 3195 E (Appellant) : (Respondent) Appellant By : Shri Dharmesh Shah & Ms. Mitali Parekh Respondent By : Shri Arun Kranti Datta – Cit Dr Date Of Hearing : 13.01.2026 Date Of Pronouncement : 23.01.2026 O R D E R Per Saktijit Dey: The Captioned Appeal By The Revenue Arises Out Of Order Dated 29.07.2024, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y. For Short) 2021-22. 2. There Is Delay Of Four Days In Filing The Appeal. After Considering The Submissions Of The Parties, We Are Satisfied That The Delay In Filing The Appeal Was Due To Reasonable Cause. Hence, We Condone The Delay & Admit The Appeal For Adjudication On Merits. The Grounds Raised By The Revenue Are As Under: (I) "Whether On The Facts & In The Circumstances Of The Case, The Cit(A) Erred In Holding That Both The Assessing Officers In Their Remand Report Have Not Given Adverse Findings Against The Assessee On The Issue Of Long Term Capital Loss Carried Forward, When In Fact Both Of Them Have Categoricaly Disagreed With The Submissions Made By The Assessee."

For Appellant: Shri Dharmesh Shah &For Respondent: Shri Arun Kranti Datta – CIT DR

filing the appeal. After considering the submissions of the parties, we are satisfied that the delay in filing the appeal was due to reasonable cause. Hence, we condone the delay and admit the appeal for adjudication on merits. The grounds raised by the Revenue are as under: (i) "Whether

Satara Zilla Dak Karmachari Sahakari Pathsanstha, Near Suruchi Banglow, Shukrawar Peth, Satara vs. Assessing Officer Ward 2, Aaykar Bhawan, Manjunath Manor, Pawai Naka, Satara

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

ITA 2829/PUN/2025[2018-19]Status: DisposedITAT Pune22 Jan 2026AY 2018-19

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2829/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Satara Zilla Dak Karmachari Vs. Ito, National E- Sahakari Pathsanstha, Assessment Centre, 117/B, Near Suruchi Delhi. Banglow, Shukrawar Peth, Satara- 415002. Pan : Aapas2980K Appellant Respondent Assessee By : Shri Rajkumar Doshi Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing 13.01.2026 : Date Of Pronouncement : 22.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 24.09.2025 Which Is Arising Out Of The Assessment Order U/S 144 R.W.S. 143(3A) & 143(3B) Of The Act For Assessment Year 2018-19 Framed On 12.04.2021 By The Ito, National E-Assessment Centre, Delhi. 2. The Effective Grounds Of Appeal Raised By The Assessee Is Against The Disallowance Of Deduction Of Rs.43,54,979/- Claimed U/S 80P Of The Act. In The Grounds Of Appeal, The Assessee Also Stated That In Its Own Case For A.Y. 2020-21, Ld. Cit(A) Has Allowed The Deduction U/S 80P Of The Act. Further, The Request Has Been Made

For Appellant: Shri Rajkumar DoshiFor Respondent: Shri Shashank Ojha (Virtual)
Section 143(2)Section 144Section 80PSection 80P(2)(a)

Admittedly, during the Covid-19 Pandemic period there were restriction of movement of general public and the assessee had a reasonable cause for not replying to the notice issued by the Assessing Officer, which resulted into passing of best judgement assessment. Further, on account of Covid-19 Pandemic, the appeal

Salma Sadiq Kantharia, Mumbai vs. ITO - Ward 41(1)(4), Kautilya Bhavan, Mumbai

In the result, the appeal is allowed for statistical purpose

ITA 7403/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Jan 2026AY 2020-21

Bench: Shri Saktijit Dey & Shri Jagadishsalma Sadiq Kantharia Ito-Ward 41(1)(4) A/06, 1St Floor, Shamsuddin Nagar, Kautilya Bhavan, C41-43, Andheri Kurla Road, Jari Mari Kurla, Avenue 3, Near Videsh Bhavan, Mumbai-400 072 Vs. G Block, Bkc, Gilban Area, Bandra Kurla Complex, Bandra E, Mumbai-400 051 Pan/Gir No. Andpk 5832 A (Appellant) : (Respondent) Appellant By : Shri Piyush Chhajed & Shri Ayush Chhajed Respondent By : Shri Swapnil Choudhari Date Of Hearing : 22.01.2026 Date Of Pronouncement : 22.01.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 27.05.2024 Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2021-22. 2. Before We Proceed To Deal With The Appeal, We Notice That There Is A Delay Of 471 Days In Filing The Appeal. The Assessee Has Sought Condonation Of Delay By Furnishing An Affidavit, Explaining The Reason For Delay. It Is The Case Of The Assessee That In The Appeal Memo, In Form No. 35, The Address Of Communication Was That Of Assessee’S Tax Consultant, Ca Niranjan R Shah. However, Being An Elderly Person, Suffering From Prolonged Illness

For Appellant: Shri Piyush Chhajed &For Respondent: Shri Swapnil Choudhari

affidavit of the assessee and the other materials on record, we are convinced that the delay in filing the appeal was due to reasonable cause. Hence, we are inclined to condone the delay and admit the appeal for adjudication. Insofar as the appeal is concerned, the primary grievance