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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

Xerago E-Biz Services Pvt. Ltd., Chennai vs. ITO, Corporate Ward-3(3), Chennai

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

ITA 4067/CHNY/2025[2021-22]Status: DisposedITAT Chennai27 Feb 2026AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 4067/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 Xerago E-Biz Services Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward 3(3), Plot No.80 & 93, Developed Plot, Chennai Xerago Towers, Industrial Estate, Perungudi, Chennai – 600 096 Pan: Aaacx 0387J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri H. Yeshwanth Kumar, Advocate ""यथ" क" ओर से/Respondent By : Shri Aroon Praasad, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 25.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 27.02.2026 आदेश/ O R D E R Per George George K, Vp: This Appeal Filed By The Assessee Is Directed Against The Addl./Jcit(A), Varanasi Order Dated 31.10.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2021-22. :- 2 -: 2. The Grounds Raised Read As Follows:- 1. For That The Order Of The Additional / Joint Commissioner Of Income Tax (Appeals) Is Contrary To Law, Facts & Circumstances Of The Case & At Any Rate Is Opposed To The Principles Of Equity, Natural Justice & Fair Play.

For Appellant: Shri H. Yeshwanth KumarFor Respondent: Shri Aroon Praasad, Addl.CIT
Section 143(1)Section 154Section 250Section 90

appeal as time barred. 4. For that the Additional / Joint Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had a reasonable cause for the delay in filing the appeal. 5. For that the Additional / Joint Commissioner of Income Tax (Appeals) failed to appreciate that the appellant could ... filed before the FAA belatedly was on account of assessee pursuing an alternative remedy. When assessee was pursuing an alternative remedy, there is sufficient / reasonable cause for the delay in filing the appeal before the FAA and no latches can be attributed to the assessee company. As regards the issue

Tool Tech Enteprises Pvt. Ltd., Coimbatore vs. ITO, Corporate Ward-1, Coimbaotore

In the result, the appeal filed by the assessee is dismissed

ITA 3866/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Feb 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3866/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Tool Tech Enterprises Private Limited, Vs. The Income Tax Officer, No. 374, A P Tower, Dr. Rajendra Corporate Ward 1, Prasad Road, 100 Feet Road, Coimbatore. Gandhipuram, Coimbatore 641 012. [Pan: Aadct9931H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V. Padmanabhan, Ca ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 27.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.01.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 963 Days. The Assessee Filed Petition For Condonation Of Delay In Support Of Notarized Affidavit. In The Petition, The Assessee Has Submitted As Under:

For Appellant: Shri V. Padmanabhan, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144Section 253

support of the above submission, no documentary evidence like closure of business, etc. is placed on record and we do not find any reasonable cause for the inordinate delay of 963 days in filing the appeal. 5 I.T.A. No.3866/Chny/25 6. We find time and again, the Hon’ble Supreme Court ... established principle where an appeal presented with abnormal delay, beyond limitation, the assessee has to explain as to what is the reasonable cause, which really prevented the assessee to approach the appellate authority within time. As we discussed above, since the assessee failed to give sufficient cause for not filing