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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

Chelaram Balwani, Rathi Building Ke Pass vs. Commissioner of Income Tax (Appeals), Delhi

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

ITA 194/AGR/2025[2013-14]Status: DisposedITAT Agra28 Oct 2025AY 2013-14

Bench: Shri S.Rifaur Rahman & Shri Sunil Kumar Singhshri Chelaram Balwani, Vs. Ito, Ward 1 (3), Rathi Building Ke Pass, Gwalior. Ward No.8, Ajay Pal Ki Gali, Datia, Gwalior – 475 661 (Madhya Pradesh). (Pan : Aynpb7221P) (Appellant) (Respondent) Assessee By : Shri Alok Dhingra, Advocate Revenue By : Shri Shailendra Srivastava, Sr. Dr Date Of Hearing : 14.10.2025 Date Of Order : 16.10.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 10.01.2024 For The Assessment Year 2013-14. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Brought To Our Notice That There Is A Delay Of 395 Days In Filing The Appeal Before The Tribunal On The Ground That The Order Was Communicated Via Portal & The Registered Mail Id I.E. 71Nkkhare@Gmail.Com On The Income Tax Portal Does Not Belong To The Assessee, It Might Have Been Of Erstwhile Consultant Who

For Appellant: Shri Alok Dhingra, AdvocateFor Respondent: Shri Shailendra Srivastava, Sr. DR
Section 147

rival submissions and the application for condonation of delay. After going through the application for condonation of delay, we observe that there was a reasonable cause in filing the appeal belatedly and accordingly, we are inclined to condone the delay. 5. At the outset, it was submitted

Shivam Multispeciality and Accident Care Centre Pvt. Ltd., Pune vs. Income Tax Officer, Pune

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

ITA 696/PUN/2025[2017-2018]Status: DisposedITAT Pune27 Oct 2025AY 2017-2018

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.696/Pun/2025 धििाारण वर्ा / Assessment Year : 2017-18 Shivam Multispecialty & Accident Care Income Tax Officer, Centre Pvt. Ltd., Ward – 6(1), Pune Opp. Manali Resort, Near Dsk Dream City, Vs. Next To Loni Kalbhor Toll Naka, Pune-Solapur Mumbai Bypass Road, Fursungi, Pune-412308, Maharashtra Pan : Aapcs5482A अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Dhiraj Dandgaval Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

For Appellant: Shri Dhiraj DandgavalFor Respondent: Shri Akhilesh Srivastva
Section 143(2)Section 144Section 68

delay in filing of the appeal before the Ld. CIT(A) / NFAC, he dismissed the same on the ground that there was no reasonable cause shown by the assessee for delay in filing of the appeal. It is the submission of the Ld. Counsel for the assessee that the delay ... deliberate but has occurred due to the reason(s) mentioned in the preceding paragraph and thus there was a reasonable cause on the part of the assessee. 8. We find the Hon'ble Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. reported