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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

Jhansi Lakshmi Ramanadham, Hyderabad vs. ITO., Ward-8(1), Hyderabad

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

ITA 886/HYD/2025[2015-16]Status: DisposedITAT Hyderabad10 Dec 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.886/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Smt. Jhansi Lakshmi Vs. Income Tax Officer Ramanadham Ward 8 (1) Hyderabad Hyderabad Pan:Acbpr3566K (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Sandhya राज" व "ारा/Revenue By:: Shri Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 04/12/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Jhansi Lakshmi Ramanadham, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 30.05.2024 For The A.Y 2015-16. 2. At The Outset, It Is Seen That There Is A Delay Of 292 Days In Filing The Present Appeal Before This Tribunal. The Assessee Has Filed An Affidavit Explaining The Reasons For The Delay. The Learned Authorized Representative (“Ld. Ar”) Submitted That The Assessee Is Page 1 Of 12

For Appellant: Advocate S. SandhyaFor Respondent: : Shri Arun Kumar, Sr. DR

submitted that delay cannot be condoned in the absence of sufficient cause and that the assessee has failed to demonstrate any reasonable cause. Accordingly, the delay should not be condoned and the appeal deserves dismissal on limitation. 5. We have carefully considered the rival submissions and the material available

Dosjibhai Chellabhai Patel, Mumbai vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 6517/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Dec 2025AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2018-19 Dosjibhai Chellabhai Patel, Commissioner Of Income Tax 2/201, Surbhi Apartment, (Appeals), Dafatry Road, Vs. Nfac, Delhi Malad East, Mumbai-400097. Pan : Aadpp5454C (Appellant) (Respondent) For Assessee : Ms. Mansi Joshi For Revenue : Ms. Nidhi Agarwal, Sr.Dr (Virtually Present) Date Of Hearing : 04-12-2025 Date Of Pronouncement : 10-12-2025 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)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 30-07-2025, Pertaining To Assessment Year (Ay) 2018-19. 2. At The Outset, It Is Noted That There Is A Delay Of 11 Days In Filing The Appeal As Pointed Out By The Registry. After Hearing Both The Parties & Perusing The Material 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: Ms. Mansi JoshiFor Respondent: Ms. Nidhi Agarwal, Sr.DR
Section 143(2)Section 144Section 50C

appeal as pointed out by the Registry. After hearing both the parties and perusing the material 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

Radheshyam Shyamlal Gupta, Mumbai vs. Income Tax Officer, WD-11(2)(2), Mumbai

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

ITA 6103/MUM/2025[2012-13]Status: DisposedITAT Mumbai10 Dec 2025AY 2012-13

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2012-13 Radheshyam Shyamlal Gupta, Income Tax Officer, 5Th Floor, Ward-11(2)(2), Anuradha Satyamurty Residency Vs. Aayakar Bhavan, Plot No.16, N.S. Road No.11, M.K.Road, Jvpd Scheme, Juhu, Mumbai-400020. Mumbai-400049. Pan : Aabpg4019L (Appellant) (Respondent) For Assessee : Shri Jay Thakkar For Revenue : Shri Brajendra Kumar Date Of Hearing : 02-12-2025 Date Of Pronouncement : 10-12-2025 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)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 04-07-2025, Pertaining To Assessment Year (Ay) 2012-13. 2. Briefly Stated, Facts Of The Case Are That Assessment In This Case Was Completed U/S. 143(3) R.W.S. 147 Of The Income Tax Act, 1961 („The Act‟), Wherein The Ao Has Determined The Long Term Capital Gain At Rs. 37,21,230/-, Being The 50% Share Of The Assessee In Respect Of Transfer Of 2 Property, Namely, Flat No. 2A & 2B, Anuradha Satyamurty Residency, Plot No.16, 11Th Road, Juhu, Vile Parle (West), Mumbai, Which The Assessee Has Sold Jointly With His Wife, Mrs. Shubhadra R. Gupta. The Assessee Thereafter Carried The Matter In Appeal Before The Ld.Cit(A), Who Has Since Sustained The Order Of The Ao & Dismissed The Appeal Filed By The Assessee On Account Of Delay. Against The Said Order, The Assessee Is In Appeal Before Us.

For Appellant: Shri Jay ThakkarFor Respondent: Shri Brajendra Kumar
Section 143(3)

supporting documents filed before the Ld.CIT(A), Court Rozanama, EOW proceedings, proceedings before MPID court and other documents, which substantiate that there was a reasonable cause for the delay in filing the appeal. It was submitted that the assessee be allowed one more opportunity and the matter may be remitted