← All Phrases

“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

Global University Foundation, Hyderabad vs. ITO., Exemption Ward-1(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 240/HYD/2025[2021-22]Status: DisposedITAT Hyderabad26 Sept 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No. 240/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2021-22) Global University Foundation Vs. Income Tax Officer Hyderabad (Exemption) Ward-1 Pan:Aaicg0020F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Suvibha Nolka राज" व "ारा/Revenue By:: Shri Sankar Pandi, P, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 11/09/2025 घोषणा की तारीख/Pronouncement: 26/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal By The Assessee Is Directed Against The Order Dated 14/07/2023 Of The Learned Cit (A)-Nfac Delhi, For The A.Y.2021-22. 2. There Is A Delay Of 506 Days In Filing The Present Appeal. The Assessee Has Filed A Petition For Condonation Of Delay Which Is Supported By An Affidavit Of The Director Of The Assessee Foundation. The Learned Counsel For The Assessee Has Submitted That The Assessee Was Not Served With The Impugned Order Dated 14/07/2023 Passed By The Learned Cit (A) & Therefore, Due To The Non-Communication Of The Impugned Order, The Assessee

For Appellant: CA Suvibha NolkaFor Respondent: : Shri Sankar Pandi, P, Sr.AR
Section 11Section 143(1)

learned CIT (A) for the A.Y 2021-22. Thus, he has contended that the assessee has failed to explain any sufficient or reasonable cause for an inordinate delay of 506 days in filing the appeal. Thus, the learned DR has vehemently opposed to the condonation of delay. 4. We have ... authorities concerned to consider the explanation and give a specific finding whether the explanation so provided is satisfactory or whether the explanation provides reasonable cause which prevented the petitioner in filing Form 10B within the stipulated period of time. 11. The judgment of this High Court in the case

M/S. Rukmani Finance Pvt Ltd., Bengaluru vs. Income Tax Officer, Ward-5(1)(4), Bangalore

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

ITA 919/BANG/2025[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year :2017-18 M/S. Rukmani Finance Pvt. Ltd. No.84, 5Th Floor, Manish Tower Ito J.C. Road Vs. Ward 5(1)(4) Bengaluru 560 002 Bengaluru Pan No : Aaacr9552P Appellant Respondent Appellant By : Sri T. Srinivasa, A.R. Respondent By : Sri Subramanian, D.R. Date Of Hearing : 30.06.2025 Date Of Pronouncement : 26.09.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 31.05.2023 Vide Din & Order No. Itba/Nfac/S/250/2023-24/1053354784(1) Passed U/S. 250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: M/S. Rukmani Finance Pvt. Ltd., Bengaluru Page 2 Of 11

For Appellant: Sri T. Srinivasa, A.RFor Respondent: Sri Subramanian, D.R
Section 250Section 253(5)

assessee for not presenting the appeal within the prescribed time. The explanation, therefore, becomes relevant to determine whether the same reflect sufficient and reasonable cause on the part of the assessee in not filing this appeal within the prescribed time. 6.1 While considering a similar issue the Apex Court ... whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for not filing the appeal. We have to see the cause for the delay. When there was a reasonable cause, the period of delay

New Life Grace Ministries Trust, Sindhdurg vs. CIT (Exemption), Pune

In the result appeal of the assessee is allowed for statistical purposes

ITA 889/PUN/2025[2024-2025]Status: DisposedITAT Pune25 Sept 2025AY 2024-2025

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील स ./ Ita No.889/Pun/2025 धििेंारण वर्ा /Assessment Year: 2024-2025 New Life Grace Ministries Cit (Exemption), Pune Trust, Humarmala, Anav, Vs. Kudal, Sindhdurg- 416510 Maharashtra Pan-Aabtn4941L अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: None Department By: Shri Amol Khairnar, Cit-Dr Date Of Hearing: 25-09-2025 Date Of Pronouncement: 07-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit (Exemption), Pune Passed U/S 12Ab/(I)(B)(Ii) Of The Income-Tax Act, 1961 Dated 10.09.2024. 2. When The Case Called For None Appeared On Behalf Of The Assessee However Written Submissions Alongwith The Application For Condonation Of Delay Stands Duly Submitted.

For Appellant: NoneFor Respondent: Shri Amol Khairnar, CIT-DR
Section 12ASection 12A(1)(ac)

hearing shall be given to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Grounds of appeal raised by the assessee are allowed for statistical purposes. 10. In the result appeal of the assessee is allowed for statistical purposes