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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

Narendra Singh Bisht, Gomtinagar vs. ACIT- 1, Lucknow-New, Lucknow

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

ITA 63/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.63/Lkw/2025 ननिाारण वर्ा/ Assessment Year: 2017-18 Narendra Singh Bisht V. Acit-1, Lucknow New 123, Khargapur, Gomtinagar, Aayakar Bhawan, Ashok Malesemau, Uttar Pradesh- Marg, Lucknow-226001. 226010. Pan:Aljpb0987D अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Ashwani Jaiswal, C.A. प्रत्यर्थी कक और से /Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 04 11 2025 घोर्णा कक तारीख/ Date Of 30 12 2025 Pronouncement:

For Appellant: Shri Ashwani Jaiswal, C.AFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 142(1)Section 144Section 282Section 68

assessment year 2017-18. The assessee has raised the following grounds of appeal: - “1. Because the assessee was prevented by sufficient and reasonable cause in non-complying the notice issued under section 142(1) of the Act, as the notices issued were never served on the appellant, the Assessing Officer ... Looking to these facts and medical certificate issued by the medical practitioner, we are of the vew that there was a reasonable cause for assessee that prevented him from filing the present appeal within the prescribed time line. We, therefore, respectfully following the judgment of the Hon'ble Supreme Court

M.K. Wood Trading Corporation, Lucknow vs. DCIT/ACIT-1, Lucknow

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

ITA 504/LKW/2025[2020-21]Status: DisposedITAT Lucknow31 Dec 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 M. K. Wood Trading Corporation V. The Dcit/Acit-1 10, Basha Khera Lucknow New Takrohi, Indira Nagar Lucknow (U.P) Tan/Pan:Aarfm2443G (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 07.08.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Partnership Firm Engaged In The Business Of Timber Products. The Assessee Filed Its Return Of Income For The Year Under Consideration On 10.12.2020 Declaring A Total Income Of Rs.54,030/-. The Case Of The Assessee Was Selected For Scrutiny Assessment And, Accordingly, The Assessing Officer (Ao) Issued Statutory Notices To The Assessee. However, There Was No Response From The Side Of The Assessee. The Ao Finally Issued Show Cause Notice Under Section 144 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) Dated 21.3.2022, Vide Which The Ao

For Respondent: Shri R.R.N. Shukla, D.R
Section 143(3)Section 144Section 144BSection 68

reach the hands of the assessee in as much as the assessee being unaware of the said emails, being prevented by sufficient and reasonable cause, the order passed by the CIT(A) be set aside. 3. Because the notices u/s 250 have not been issued and served physically, more