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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

Binukala Sivarajendran, Thiruvananthapuram vs. The Income Tax Officer, Thiruvananthapuram

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

ITA 865/COCH/2025[2019-20]Status: DisposedITAT Cochin28 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Binukala Sivarajendran .......... Appellant Arun Gardens, Vellamkettuvila, Nemom P.O. Thiruvananthapuram [Pan: Djdps8683E] Vs. Ito, Ward-2(1), Thiruvananthapuram .......... Respondent Assessee By: Shri Mathew Joseph, Ca Revenue By: Ms. Neethu S. Sr. Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 21.03.2025 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income For Ay 2019-20 Was Filed By The Appellant. Based On The Information That The Appellant Purchased Bonds/Debentures Valued At Rs. 20,00,000/- During Previous Year Relevant To The Assessment Year Under Consideration, The Ao Formed An Opinion That Income Escaped Assessment To Tax. Therefore, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued

For Appellant: Shri Mathew Joseph, CAFor Respondent: Ms. Neethu S. Sr. DR
Section 147Section 148Section 148A

would be evident that the CIT(A) dismissed the appeal without discussing as to how the said explanation does not constitute reasonable cause, merely dismissed the appeal which is untenable in law. Therefore, I restore the matter back to the file of the CIT(A) to decide the issue

Midhun Krishnan, Thiruvananthapuram vs. ITO Ward 1(2), Thiruvananthapuram

In the result, appeal filed by the assessee is allowed

ITA 730/COCH/2025[2017-18]Status: DisposedITAT Cochin28 Nov 2025AY 2017-18

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Hon’Ble Manu Kumar Giriआयकर अपील सं./ Ita No.730/Coch/2025 "नधा"रण वष" /Assessment Year: 2017-18 Midhun Krishnan, The Income Tax Officer, Tc 26/1520, Sakthi Nivas, Vs. Ward-1(2), Rishimangalam, Trivandrum. Vanchiyoou, Trivandrum – 695 035. Pan: Bbepk 8886L (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Kmv Pandalai, Advocate ""यथ" क" ओर से /Respondent By : Smt. Leena Lal, Snr Ar सुनवाई क" तार"ख/Date Of Hearing : 04.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 28.11.2025 आदेश / O R D E R Per Manu Kumar Giri ():

For Appellant: Shri KMV Pandalai, AdvocateFor Respondent: Smt. Leena Lal, Snr AR
Section 143(3)Section 269SSection 271DSection 273BSection 54

return of income. The entire sales proceeds were invested in construction of a residential house (claimed u/s 54). 4. The assessee has taken a ‘reasonable Cause’. The circumstances show that the assessee had no prior intention of accepting cash. The buyer brought cash suddenly on the date of registration, leaving ... evidencing bona fides. The assessee disclosed the entire transaction in the return of income, removing any possibility of tax evasion. These facts establish reasonable cause within the meaning of section 273B. Judicial precedents consistently hold that where the identity of the payer, genuineness of the transaction, and source of funds