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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

Lakshmi Sadho Commercial Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 443/KOL/2025[2015-16]Status: DisposedITAT Kolkata08 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarmalakshmi Sadho Commercial Pvt. Vs Ito, Ward-10(2), Kolkata Ltd. 134, Ashutosh Mukherjee Road, Kol-25. Pan No. : Aabcl6120C (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Rajkumar Agarwal, Ar राज"व क" ओर से /Revenue By : Shri Manoj Kr. Patil, Jcit, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 10/09/2025 घोषणा क" तार"ख/Date Of Pronouncement : 08/12/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : This Appeal By The Assessee Arises Against The Order Dated 22.01.2025 Of The National Faceless Appeal Centre (Hereinafter Referred To As The ‘Cit(A)’) Passed Under Section 250 Of The Income- Tax Act, 1961 (The ‘Act’). 2. Brief Fact Of The Case Are That During The Course Of Assessment Proceedings, It Was Noticed That The Assessee Had Shown A Property Valued At ₹1,35,95,500, Whereas The Fair Market Value Was Determined At ₹1,47,77,500 For The Purpose Of Stamp Duty. In The Return Of Income, The Assessee Had Declared The Nature Of Business As Trading Under Code 204. Based On This Declaration, The Assessing Officer Held That The Assessee Was Required To Get Its Accounts Audited As Per Section 44Ab Of The Act. The Assessing Officer Issued Notice Under Section 274 R.W.S.

For Appellant: Shri Rajkumar Agarwal, ARFor Respondent: Shri Manoj Kr. Patil, JCIT, Sr. DR
Section 250Section 271BSection 273BSection 274Section 44A

receipts were business receipts, the assessee was under a bona fide belief that such receipts were capital in nature. Besides that where constitutes reasonable cause within the meaning of section 273B of the Act, no penalty could be levied. 5. On the other hand, the learned DR supported the orders ... mechanically applied. Further, section 273B of the Act provides that no penalty shall be imposed if the assessee proves that there was a reasonable cause for the default. In the present case, whether the receipts constitute business income or capital receipts is itself debatable. The assessee’s bona fide belief

Ramita Chaudhuri, Haryana vs. Income Tax Officer-Ward 69(1), Delhi

The appeal of the assessee is partly allowed for statistical purposes

ITA 4392/DEL/2025[2021-22]Status: DisposedITAT Delhi05 Dec 2025AY 2021-22

Bench: Shri Mahavir Singh & Shri Manish Agarwalincome Tax Officer, Ramita Chaudhuri, Ward-69(1), Block C-1, Flat No.1002, Vs. Delhi. The Legend, Sector-57, Gurgaon. Pan-Aappc4405P (Appellant) (Respondent) Assessee By Shri Anil Sethi, Ca Department By Shri Krishna Kumar Ramawat, Sr. Dr Date Of Hearing 03/12/2025 Date Of Pronouncement 05/12/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Gwalior (‘Ld. Cit(A)’ In Short), Dated 18.03.2025 In Appeal No. Nfac/2020-21/10197234 For Assessment Year 2021-22. 2. From The Perusal Of The Record, It Is Seen That Filing The Appeal Is Delayed By 55 Days, For Which Condonation Application Is Filed. In The Said Application, It Is Stated That When The Order Of Ld. Cit(A) Was Served Upon The Assessee She Was Residing Abroad In Madrid, Spain & Was Not In India. She Returned To India On 20Th June, 2025 From Span. Due To This Reason, The Delay Of 55 Days Was Occurred In Filing The Appeal Before The Tribunal. The Assessee Also Filed An Affidavit In Support Of The Ramita Chaudhuri Vs. Ito Averments Made In The Application For Condonation Of Delay. Considering The Facts & Explanation Given In The Application, We Find That Assessee Has Been Able To Demonstrate That There Is Reasonable Cause In Filing The Appeal Delayed. Considering These Facts, We Condoned The Delay & Admit The Appeal For Adjudication On Merits.

condonation of delay. Considering the facts and explanation given in the application, we find that assessee has been able to demonstrate that there is reasonable cause in filing the appeal delayed. Considering these facts, we condoned the delay and admit the appeal for adjudication on merits. 3. Heard both