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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

Century Pharmaceuticals Ltd., Vadodara vs. Assessment Unit, Income Tax Department Present Jurisdiction the DCIT, Circle-1(1)(1), Vadodara

ITA 867/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2016-17

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita No. 867/Ahd/2024 िनधा"रण वष"/Assessment Year: 2016-17 Century Pharmaceuticals Ltd., बनाम Assessment Unit, 406, World Trade Centre, Income Tax Department Vs. Sayajigunj, Vadodara Represented Through Gujarat-390005 Dcit, Circle-1(1)(1), Baroda Pan: Aaacc 7646 K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Shri M.J. Shah & Shri Rushin Patel, Ars िनधा"रती की ओर से / Assessee By : Shri Hrishikesh Hemant Patki, Sr Dr ""थ" की ओर से / Revenue By: सुनवाई क" तारीख/Date Of Hearing : 24/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 30/07/2024 आदेश/O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short Referred To As “Ld. Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 [In Short Referred To As “The Act”] Dated 26.02.2024, Confirming The Levy Of Penalty Of Rs.1,50,000/- U/S 271B Of The Act, For Delayed Furnishing Of Tax Audit Report As Required U/S 44Ab Of The Act, Pertaining To Assessment Year (Ay) 2016-17. 2. The Grounds Raised By The Assessee Are Descriptive & Argumentative In Nature. I Am, Therefore, Reproducing Only The Highlighted Portion Of The Grounds Of Appeal Which Are As Follows:- “1. On The Facts & On The Facts & In The Circumstances Of Your Appellant’S Case & In Law, The Honorable Cit-Appeals (Nfac) Has Erred In Confirming The Action Of The Ld. Ao Of Invoking Provision Of Section 271B, In Our Case After The Six Years By Violating The Provision Of The Section 275(1) Of The Act.

For Appellant: Shri Hrishikesh Hemant Patki, Sr DR
Section 139(1)Section 250Section 271Section 271BSection 275(1)Section 44A

true. This fact was never disputed before us. The only contention of the ld. Counsel for the assessee before us was that there was reasonable cause for the delay which was explained in detail to the authorities below, but both the Assessing Officer and the ld. CIT(A) found ... orders of the Assessing Officer and ld. CIT(A). 6. Since the entire case of the assessee rests on the fact that there was reasonable cause adduced by the assessee for the delay in filing the Tax Audit Report which was not accepted by the Revenue, it is necessary

Ushaben Prakashkumar Shah, Ahmedabad vs. The Income Tax Office, Ward-1(3)(1), Ahmedabad

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

ITA 340/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2012-13

Bench: Smt.Annapurna Guptaasstt.Year :2012-13 Ushaben Prakashkumar Shah Ito, Ward-1(3)(1) C/O. M.S. Chhajed & Co., Ca Vs Ahmedabad. “Kamal Shanti” Nr.Sardar Patel Statute Ahmedabad. Pan : Blrps 2392 J (Applicant) (Responent) : Shri Chhajed, Ar Assessee By : Revenue By Shri Hrishikesh Hemant Patki, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 25/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 30/07/2024 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Revenue by Shri
Section 144Section 147Section 148Section 249(4)(b)Section 250Section 68

cash found deposited in her bank account under section 68 of the Act. The ld.counsel for the assessee admitted that the there was no reasonable cause as such with the assessee for not having participated in the assessment proceedings, but at the same time, pleading that since the matter ... payment, I find is not correct in law. Moreover, the assessee has not appeared before the AO also in assessment proceedings, and since no reasonable cause has been adduced for the same, I consider it fit case for imposing cost of Rs.2,000/- on the assessee. Also considering that

Ramareddy Dasharatha, Lakshmisagara Neralur Post vs. The Additional Commissioner of Income Tax, Bengaluru

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

ITA 873/BANG/2024[2015-16]Status: DisposedITAT Bangalore30 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2015-16

For Appellant: Advocate &For Respondent: Shri Subramanian .S, JCIT-DR
Section 263Section 269SSection 269TSection 271Section 271DSection 273B

assessee, the Ld.AO passed penalty order u/s 271D levying penalty as the assessee violated provisions of Section 269SS, and for want of reasonable cause as contemplated under provision of sec.273B of the Act. Page 4 of 7 Aggrieved by the order of the Ld.AO, assessee filed appeal before the Ld.CIT ... exigency that existed wherein assessee required the cash to be accepted. He thus prayed for the penalty to be deleted due to the reasonable cause made u/s. 273B i.e. established for accepting the loan in cash. 3.2 On the contrary, the Ld.DR submitted that there is a contravention

Aman Chambers Premises Co-Op Soc Ltd, Charni Road Mumbai vs. The Ass. Director of Income Tax Bengaluru, Bengaluru

In the result, ITA No. 2077/MUM/2024, ITA No

ITA 2080/MUM/2024[2020-2021]Status: DisposedITAT Mumbai30 Jul 2024AY 2020-2021

Bench: Shri.Narendra Kumar Billatya & Shri. Raj Kumar Chauhan

Section 249(2)Section 250

respectively. . The Ld. CIT(A) in each appeal was of the opinion that the assessee has failed to show any sufficient and reasonable cause of Condonation of Delay and accordingly the appeals were dismissed as non-maintainable and hence not admitted. . We have heard the Ld. AR on behalf

Aman Chambers Premises Co-Op Soc. Ltd., Charni Road Mumbai vs. The Asst. Director of Income Tax, Bengaluru

In the result, ITA No. 2077/MUM/2024, ITA No

ITA 2078/MUM/2024[2021-2022]Status: DisposedITAT Mumbai30 Jul 2024AY 2021-2022

Bench: Shri.Narendra Kumar Billatya & Shri. Raj Kumar Chauhan

Section 249(2)Section 250

respectively. . The Ld. CIT(A) in each appeal was of the opinion that the assessee has failed to show any sufficient and reasonable cause of Condonation of Delay and accordingly the appeals were dismissed as non-maintainable and hence not admitted. . We have heard the Ld. AR on behalf

Aman Chambers Premises Co-Op Soc Ltd., Charni Road Mumbai vs. The Assitant Director of Income Tax, Bengaluru

In the result, ITA No. 2077/MUM/2024, ITA No

ITA 2077/MUM/2024[2019-2020]Status: DisposedITAT Mumbai30 Jul 2024AY 2019-2020

Bench: Shri.Narendra Kumar Billatya & Shri. Raj Kumar Chauhan

Section 249(2)Section 250

respectively. . The Ld. CIT(A) in each appeal was of the opinion that the assessee has failed to show any sufficient and reasonable cause of Condonation of Delay and accordingly the appeals were dismissed as non-maintainable and hence not admitted. . We have heard the Ld. AR on behalf

Tushar Jayantilal Lakhani, Mumbai vs. Commissioner of Income Tax (Appeals), NFAC

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

ITA 4709/MUM/2023[2016-2017]Status: DisposedITAT Mumbai30 Jul 2024AY 2016-2017

Bench: Shri B.R. Baskaran & Shri Sunil Kumar Singh: A.Y : 2016-17

For Appellant: Shri Tushar J. LakhaniFor Respondent: Shri P.D. Chougule
Section 36(1)(vii)Section 36(2)

appeal. We also heard Ld D.R. Having regard to the submissions made by the assessee, we are of the view that there was reasonable cause for the assessee in filing the appeal belatedly. Accordingly, we condone the delay and admit the appeal for hearing. 3. We heard the parties

Neetu Gupta, Punjab vs. ITO, Ward-3(1), Gurgaon

ITA 208/DEL/2024[2011-12]Status: DisposedITAT Delhi30 Jul 2024AY 2011-12

Bench: Shri G S Pannu & Shri Sudhir Pareek

For Appellant: NoneFor Respondent: Shri Govind Singhal, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 271Section 271(1)(b)Section 274

appellant had Page 2 of 10 ITA No.- 208/Del/2024 Neetu Gupta. defaulted in regard to various statutory notices issued to her without any reasonable cause. 4. We heard Learned DR and carefully scanned the material available before us. 5. On behalf of the assessee/appellant, on dated 02.05.2024 written arguments filed

Ratika Saxena, New Delhi vs. ITO Ward - 34(4), New Delhi

In the result, this appeal is allowed as indicated above for

ITA 4140/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Jul 2024AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Anil Jain, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 68

ground or the other without substantiating the reason for adjournment request, the same appeal cannot be kept pending for indefinite period without any reasonable cause as also, by observing that the appellant is not interested to pursue her appeal" in respect of the adjournment applications moved/forwarded through legal modes. Thus ... being heard in favor of appellant as well as the counsel engaged. 3. That the adjournment letters moved/filed before the same authority remained with reasonable cause duly mentioned/narrated and remained proved all the times specifically on last hearing date dated 24-01-2019 when suddenly the counsel engaged fallen

Income Tax Officer, Ward -4, Amravati vs. Shri Mahesh Shankar Sorate, Daryapur

In the result, appeal filed by the Revenue is dismissed

ITA 250/NAG/2018[2013-14]Status: DisposedITAT Nagpur29 Jul 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Abhay Y. Marathe
Section 143(3)Section 269Section 269TSection 271E

hence no penalty is called for. In the case of the appellant, there were genuine and bonafide transactions and the appellant had reasonable cause for inability to repay all the loans through crossed cheques alone, as the funds were required to be repaid immediately, and depositing the funds directly into ... explained by the appellant and summarily dismissed. The Assessing Officer has also mentioned that section 2738 of I.T. Act 1961 provides that where reasonable cause exists, no penalty was leviable. On the other hand, he has not accepted the reasons provided by appellant that gave rise to the situation

Balaji Phosphates Limited, Indore vs. Dcitacit 1(1) Indore, Indore

In the result appeal of the assessee is allowed

ITA 209/IND/2024[2017-18]Status: DisposedITAT Indore29 Jul 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibalaji Phosphates Limited, Dcitacit 1(1), 305, Utsav Avenue, Indore Vs. 12/5 Ushaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aadcb5654R Assessee By Shri Subhash Jain, Ars Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 25.07.2024 Date Of Pronouncement 29.07.2024 O R D E R

Section 143(1)Section 143(1)(a)Section 154Section 234Section 40

said petition and there after the assessee was not having knowledge of the same is required to be taken into consideration as a reasonable cause for the delay in filing the appeal. Hence, in the interest of justice we condone the delay of 1769 days in filing the appeal before

Kalu Jat, Ajmer vs. ITO, Ward 2(2), Ajmer

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

ITA 747/JPR/2023[2015-16]Status: DisposedITAT Jaipur29 Jul 2024AY 2015-16

Bench: Hon,Ble Itat, Jaipur Bench On 07.12.2023 Against The Ex-Parte Order Passed By Ld. Cit(Appeals) Nfac, New Delhi, Order Dated 07.09.2023. The Appeal No. Is Ita No. 747/Jpr/2023. 2. The Present Appeal Was Filed With A Delay Of 31 Days. 3. That The Delay In Filing Of Appeal Was Due To Mistake Of Earlier Local Counsel Of Appellant, As He Did Not Filed The Appeal Well Within The Specified Time. 4. Then, On 06.12.2023, Appellant Engaged A New Counsel Of Jaipur, Ca Raghuveer Singh Poonia & On The Very Next Day The New Counsel Filed The Appeal Before Hon'Ble Itat, Jaipur Bench. 5. Therefore, The Delay In Filing Of Appeal Was Due To Mistake Of Earlier Counsel Of Appellant, Which Can Be Treated As Reasonable Cause & Bonafide Mistake Of Appellant In Good Faith In Filing The Appeal Before Hon'Ble Itat, Jaipur Bench. In View Of Above Submission Your Good Self Are Request That Kindly Consider This As Reasonable Cause To Condone The Delay & Kindly Admit The Appeal. So The Substantial Justice May Be Delivered To The Appellant." 2.2 The Ld. Ar Of The Assessee Appearing In This Appeals Submitted That The Delay Of 31 Days Is On Account Of Due To Mistake Of Earlier Local Counsel Of The Assessee, As He Did Not Inform The Assessee In Proper Time & Subsequently The Assessee Engaged A New Counsel On The Very Next Day & Filed The Appeal. Considering The Various Judicial Precedent Where In The Courts Has Considered That Change Of The New Counsel Is A Reasonable Reason & Has Considered The Delay. Even The Hon'Ble 3

Section 148ASection 56(2)(i)Section 69

Jaipur Bench. 5. Therefore, the delay in filing of appeal was due to mistake of earlier counsel of appellant, which can be treated as reasonable cause and bonafide mistake of appellant in good faith in filing the appeal before Hon'ble ITAT, Jaipur Bench. In view of above submission your ... good self are request that kindly consider this as reasonable cause to condone the delay and kindly admit the appeal. So the substantial justice may be delivered to the appellant." 2.2 The ld. AR of the assessee appearing in this appeals submitted that the delay of 31 days

Srinivasan Narayanan, Hosur vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bengaluru

In the result, all the appeals filed by the assessee stands partly allowed for statistical purposes

ITA 1012/BANG/2024[2020-21]Status: DisposedITAT Bangalore29 Jul 2024AY 2020-21

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Smt. S. Praveena, CIT-DR

passed by the Ld.AO that went unnoticed by the manager. 6. 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 ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause Page 8 of 12 ITA Nos. 1008 to 1012/Bang/2024 for not able to file the appeals within the period of limitation. The cause

Srinivasan Narayanan, Hosur vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bengaluru

In the result, all the appeals filed by the assessee stands partly allowed for statistical purposes

ITA 1011/BANG/2024[2018-19]Status: DisposedITAT Bangalore29 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Smt. S. Praveena, CIT-DR

passed by the Ld.AO that went unnoticed by the manager. 6. 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 ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause Page 8 of 12 ITA Nos. 1008 to 1012/Bang/2024 for not able to file the appeals within the period of limitation. The cause

Srinivasan Narayanan, Hosur vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

In the result, all the appeals filed by the assessee stands partly allowed for statistical purposes

ITA 1009/BANG/2024[2015-16]Status: DisposedITAT Bangalore29 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Smt. S. Praveena, CIT-DR

passed by the Ld.AO that went unnoticed by the manager. 6. 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 ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause Page 8 of 12 ITA Nos. 1008 to 1012/Bang/2024 for not able to file the appeals within the period of limitation. The cause

Srinivasan Narayanan, Hosur vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bengaluru

In the result, all the appeals filed by the assessee stands partly allowed for statistical purposes

ITA 1008/BANG/2024[2015-16]Status: DisposedITAT Bangalore29 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Smt. S. Praveena, CIT-DR

passed by the Ld.AO that went unnoticed by the manager. 6. 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 ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause Page 8 of 12 ITA Nos. 1008 to 1012/Bang/2024 for not able to file the appeals within the period of limitation. The cause

Shree Munisuvrat Swami Jain Shwetamber Murtipujakl Sangh, Mumbai vs. Income Tax Officer (Exemption), WD-2(3), Mumbai

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

ITA 2723/MUM/2024[2010-11]Status: DisposedITAT Mumbai29 Jul 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Smt Renu Jauhri

Section 144Section 153(1)

erred in not admitting the Additional Evidence u/r 46(A) of I.T. Rules, 1962 and ought to have considered the reasonable cause and bonafide reasons that had precluded the appellant to furnish the relevant documents on assessment record; 3.0 On facts and circumstances of the case

Shri Punit Kevalchand Surana, Mumbai vs. Assistant Commissioner of Income Tax, Circle-20(1), Mumbai

ITA 2324/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Jul 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale (Jm) & Shri Omkareshwar Chidara (Am)

Section 69B

file the relevant material on which he wants to rely upon. As there was no presence before the Ld. CIT(A) without any reasonable cause, cost of Rs. 5000/- is levied on assessee and he is directed to pay the same to Income Tax Department. 5. The appeal of assessee

Ashu Mathur, New Delhi vs. ITO, Ward-71(3), Delhi

In the result, appeals are allowed

ITA 623/DEL/2023[2012-13]Status: DisposedITAT Delhi29 Jul 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri S. Rifaur Rahman

Section 139(1)Section 142(1)Section 147Section 148Section 271(1)(b)Section 273B

assessee for the impugned assessment year, copy of which is placed at pages 16 & 17 of the paper book. Thus, he submitted, there was reasonable cause for non-compliance with the statutory notices. 3 ITA 622 & 623/Del/2023 4. The learned Departmental Representative strongly relied upon the observations of the departmental ... compliance with the statutory notices is understandable. Section 273B postulates that penalty u/s 271(1)(b) cannot be imposed if the assessee establishes reasonable cause for failure to do certain things. In our considered view, due to the circumstances discussed above, the non-compliance with statutory notices by the assessee

Ashu Mathur, New Delhi vs. ITO, Ward-71(3), New Delhi

In the result, appeals are allowed

ITA 622/DEL/2023[2012-13]Status: DisposedITAT Delhi29 Jul 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri S. Rifaur Rahman

Section 139(1)Section 142(1)Section 147Section 148Section 271(1)(b)Section 273B

assessee for the impugned assessment year, copy of which is placed at pages 16 & 17 of the paper book. Thus, he submitted, there was reasonable cause for non-compliance with the statutory notices. 3 ITA 622 & 623/Del/2023 4. The learned Departmental Representative strongly relied upon the observations of the departmental ... compliance with the statutory notices is understandable. Section 273B postulates that penalty u/s 271(1)(b) cannot be imposed if the assessee establishes reasonable cause for failure to do certain things. In our considered view, due to the circumstances discussed above, the non-compliance with statutory notices by the assessee