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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

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 278/PAT/2025[2013-14]Status: DisposedITAT Patna16 Oct 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

delay. After considering the submissions and I.T.A. Nos.278 to 283/Pat/2025 Aarif Ali material on record, we find that the assessee was prevented by reasonable cause in filing the appeals within the prescribed period. Accordingly, the delay in filing the appeals is condoned, and the appeals are admitted for adjudication

Seva Bharathi, Hyderabad vs. ITO., Exemption Ward 1(4), Hyderabad

In the result, ITA.No.1307/Hyd

ITA 1307/HYD/2025[2022-23]Status: DisposedITAT Hyderabad15 Oct 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.365 & 1307/Hyd/2025 िनधा"रण वष"/Assessment Year 2022-2023 Seva Bharathi, The Commissioner Of Hyderabad – 500 018. Income Tax Vs. Telangana. (Exemptions), Ward-1(4), Pan Aayts5233K Hyderabad – 500 004. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sri Harsha राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 08.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: CA Sri HarshaFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 11Section 11(2)Section 119(2)(b)Section 12ASection 143(1)Section 250

ought to have appreciated that, the delay in filing of Form 10B was due to ill medical health of the accountant. This constitutes a reasonable cause under Section 119(2)(b) of the Income Tax Act, 1961. 3. The Ld. CIT(A) erred in not giving a reasonable opportunity ... report is against principles of natural justice. 7. The Ld. CIT(A) erred in dismissing the appeal without appreciating the fact that appellant has reasonable cause for the delay in filing the Audit Report in Form No.10BB, 8. The Ld. CIT(A) erred in dismissing the appeal without appreciating