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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

Gunjan Rungta, Kushinagar vs. Income Tax Officer, Ward - 2(4), Kushinagar

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 50/VNS/2022[2012-2013]Status: DisposedITAT Varanasi10 Oct 2025AY 2012-2013

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Gunjan Rungta V. The Income Tax Officer Onkar Vatika Colony Ward 2(4) Padrauna, Kushinagar (U.P) Kushinagar Tan/Pan:Agmpr5334G (Appellant) (Respondent) Appellant By: Shri Ashish Bansal, Advocate Respondent By: Smt Amandeep Kaur, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against Order Dated 15.06.2022, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That During The Year Under Consideration The Assessee Had Purchased An Immovable Property For A Consideration Of Rs.30,50,000/-. To Examine This Transaction, The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice Under Section 148 Of The Act. However, There Was No Response From The Side Of The Assessee To The Notice Under Section 148 Of The Act. Thereafter, The

For Appellant: Shri Ashish Bansal, AdvocateFor Respondent: Smt Amandeep Kaur, D.R
Section 147Section 148Section 69

duly verified from the records submitted by the appellant, in the absence of the response being made by the appellant (due to the reasonable cause beyond her control), for the verification of the same, the matter may be remanded by this hon'ble court before the ITO, so that

Salahuddin Mohammed, Secunderabad vs. ITO., Ward-11(1), Hyderabad

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

ITA 1047/HYD/2025[2013-14]Status: DisposedITAT Hyderabad10 Oct 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1047/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2013-14) Shri Salahuddin Mohd. Vs. Income Tax Officer Secunderabad Ward 11(1) Pan: Adgpm5833N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Hemalatha K राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 07/10/2025 घोषणा की तारीख/Pronouncement: 10/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Salahuddin Mohammed, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) (“Ld.Cit(A)”) Dated 10.08.2024 For The A.Y 2013-14. 2. At The Outset, It Is Seen That There Is A Delay Of 231 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Along With An Affidavit

For Appellant: CA Hemalatha KFor Respondent: : Dr. Sachin Kumar, Sr. DR
Section 234ASection 250Section 69A

other hand, objected to the condonation of delay, contending that the reason furnished by the assessee does not constitute a reasonable cause. 4. We have carefully considered the rival submissions and perused the material available on record, including the condonation petition and the supporting medical documents filed by the assessee ... conversant with the online mode of proceedings and had to depend on professional advice. Such ignorance, when coupled with old-age infirmities, constitutes a reasonable cause for the delay. The Hon’ble Supreme Court in Vidya Shankar Jaiswal vs. ITO (supra) has held that the authorities should adopt a liberal