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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

Govinda Kumar Sarkar, Naihati vs. I.T.O., Ward - 3(2), Purulia

In the result, appeal filed by the assessee stands dismissed

ITA 2047/KOL/2025[2015-2016]Status: DisposedITAT Kolkata12 Jan 2026AY 2015-2016

Bench: Shri George Mathanआयकर अपील सं/Ita No.2047/Kol/2025 (नििाारण वर्ा / Assessment Year :2015-2016) Govinda Kumar Sarkar, Vs Ito Ward-3(2), Purulia 37, Sc Pal Road, Naihati Bannerjee Para, 24 Parganas North, West Bengal-743165 Pan No. :Aivps 2875 C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : S.K.Kamalauddin, Ar राजस्व की ओर से /Revenue By : Shri Abhijit Adhikari, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 08.07.2025 Passed By The Ld.Addl/Jcit(A)-7, Delhi For The Assessment Year 2015-2016. 2. It Was Submitted By The Ld.Ar That The Assessee Is In Appeal Before The Tribunal As The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee On Account Of Delay In Filing The Appeal Before The Ld. Cit(A) Of 3126 Days. It Was Submitted By The Ld.Ar That The Assessee Is A Retired Employee & He Was Not Having Online Access & He Has Not Been Advised Properly By His Consultant. It Was The Prayer That The Delay Before The Ld.Cit(A) May Kindly Be Condoned & The Appeal Of The Assessee May Kindly Be Disposed Off On Merits. 3. In Reply, Ld.Sr. Dr Vehemently Supported The Orders Of The Ld. Ao & Ld. Cit(A).

For Appellant: S.K.Kamalauddin, ARFor Respondent: Shri Abhijit Adhikari, Sr. DR

delay of 3126 das delay in filing the appeal before the ld. CIT(A). The assessee admittedly has not been able to given any reasonable cause for the delay. Consequently, I do not find any reason to interfere in the order of the ld. CIT(A) and I uphold

M/S Maa Travels, Bangalore vs. ACIT(OSD) Ward-1(1), Kolkata

In the result, appeal filed by the assessee stands dismissed

ITA 751/KOL/2024[2015-15]Status: DisposedITAT Kolkata12 Jan 2026AY 2015-15

Bench: Shri George Mathanआयकर अपील सं/Ita No.751/Kol/2024 (नििाारण वर्ा / Assessment Year :2015-2016) M/S Maa Travels, Vs Acit (Osd), Ward-1(1), Kolkata No.399/A, 1St Stage, 3Rd Phase, West Of Chord Road, Manjunath Nagar, Bangalore-560010 Pan No. :Aatfm 2475 Q (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : None राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 10.01.2024 Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2015-2016. 2. It Is Noticed That This Appeal Was Originally Disposed Off On 10/12/2024. None Had Appeared. The Assessee Filed A Miscellaneous Application For Recalling Of The Order Dated 09/06/2025 & The Assessee Represented & The Tribunal Was Pleased To Recall The Order. The Appeal Was Originally Posted For Hearing On 19/11/2025. When The Matter Was Called For Hearing On 19/11/2025, It Was Adjourned To 20/11/2025 At The Request Of Ld.Ar. Then It Was Adjourned To 02/12/2025 At The Request Of The Ld.Dr. On 02/12/2025 The Ar Submitted That He Would File The Necessary Paper Book, However, Till Today No Paper Book Has Been Filed. When The Matter Was Called For Hearing Today No One Represented On Behalf Of The Assessee. Consequently, This Appeal Being Heard Ex-Parte.

For Appellant: NoneFor Respondent: Shri Abhijit Adhikary, Sr. DR

parte. 2 3. The appeal has been filed belatedly by 29 days. Condonation petition has been filed. The delay being nominal and the reasonable cause has been given for delay, therefore, the delay of 29 days in filing the present appeal is condoned. 4. The assessee is operating a travel

Swami Samartha Maharaj Seva Samasthan, Kancheepuram vs. CIT, Exemptions, Chennai

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

ITA 3090/CHNY/2025[-]Status: DisposedITAT Chennai12 Jan 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपीलसं./Ita Nos.3090 & 3091/Chny/2025 Swami Samartha Maharaj Seva The Commissioner Of Income Samasthan, Vs. Tax(Exemptions), 1, Vasantham Nagar, Orikkai, Chennai. Barathiyar Street, Kancheepuram– 631 502. [Pan: Abbts-3864-Q] (अपीलाथ$/Appellant) (%&थ$/Respondent) अपीलाथ$ की ओर से/ Appellant By : Mr. J. Saravanan, Advocate %&थ$ की ओर से /Respondent By : Mr. Arv Sreenivasan, C.I.T. सुनवाई की तारीख/Date Of Hearing : 17.12.2025 घोषणा की तारीख /Date Of Pronouncement : 12.01.2026 आदेश / O R D E R Per S.R.Raghunatha, Am: These Two Appeals Are Filed By The Assessee Against Two Separate Orders Of The Learned Commissioner Of Income Tax (Exemption), Chennai [Hereinafter Referred To As “Ld.Cit(E)”] Both Dated 05.12.2024 Passed Under Section 12Ab & 80G Of The Income Tax Act,1961 Respectively.

For Appellant: Mr. J. Saravanan, AdvocateFor Respondent: Mr. ARV Sreenivasan, C.I.T
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iii)

delay be condoned. 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

Ramkumar Venugopal Investments Pvt Ltd, Mumbai vs. DCIT Central Circle 8(1), Mumbai

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

ITA 7047/MUM/2025[2009-10]Status: DisposedITAT Mumbai12 Jan 2026AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2009-10 Ramkumar Venugopal Dcit, Central Circle-8(1), Investments Pvt. Ltd., Room No.656, 2Nd Floor, Masjid Manore, Vs. 6Th Floor, 16 Homi Modi Street, Aayakar Bhavan, Fort, Maharshi Karve Road, Mumbai. Mumbai-400020. Pan : Aaccr0534P (Appellant) (Respondent) For Assessee : Shri Himanshu Gandhi & Shri Atik Jain For Revenue : Shri Annavaran Kosuri, Sr.Dr Date Of Hearing : 08-01-2026 Date Of Pronouncement : 12-01-2026 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-50, Mumbai [„Ld.Cit(A)‟], Dated 28-06-2025, Pertaining To Assessment Year (Ay) 2009-10. 2. At The Outset, It Is Noted That There Is A Delay Of 60 Days In Filing The Appeal As Pointed Out By The Registry. After Hearing Both The Parties & Perusing The Affidavit Placed On Record, We Find That There Was Reasonable Cause For The Delay In Filing The Present Appeal & Hence, The Delay Is Hereby Condoned & Appeal Is Admitted For Adjudication.

For Appellant: Shri Himanshu Gandhi and Shri Atik JainFor Respondent: Shri Annavaran Kosuri, Sr.DR
Section 143(3)

appeal as pointed out by the Registry. After hearing both the parties and perusing the affidavit placed on record, we find that there was reasonable cause for the delay in filing the present appeal and hence, the delay is hereby condoned and appeal is admitted for adjudication. 2 3. Briefly