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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

Vimal Pukhraj Jain, Mumbai vs. Income Tax Officer 42(1)(5), Mumbai

In the result, appeal of the assessee is allowed

ITA 4305/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrivimal Pukhraj Jain Income Tax Officer Ward 806, Dheeraj Enclave, Borivali East, Vs. 42(1)(5) Opp. Bhor Industries, Mumbai Kautilya Bhavan, Bkc, 400066 Mumbai 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaipj6511H (Appellant) (Respondent) निर्ााररती की ओर से / Assessee By: Shri. Pankaj Jain/ Ms. Karuna Kurle Shirdhankar /Revenue By: Ms. Kavita P. Kaushik Sr. Dr Date Of Hearing 18.08.2025 Date Of Pronouncement 25.09.2025 आदेश/O R D E R Per Renu Jauhri [A.M]: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi (Hereinafter Referred To As "Cit(A)"] Dated 14.02.2023 Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "Act"] For Assessment Year [A.Y.] 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: “On The Facts & In The Circumstances Of The Case & In Law The Ld. Commissioner Of Income Tax (Appeals) –Nfac Has Confirmed The Penalty Of Rs. 50,000/- Levied By The Assessing Officer By Invoking Provisions Of Section 272A(1)(D) Of The Income Tax Act, 1961 For Non-Compliance Of The Notices.” 3. At The Outset, It Is Notice That There Is A Delay In Filling Appeal Of 807 Days. The Assessee Has Filed An Affidavit Explaining The Reasons For The P A G E | 2

For Appellant: Shri. Pankaj Jain/ Ms. KarunaFor Respondent: Ms. Kavita P. Kaushik SR. DR
Section 143(3)Section 250Section 272ASection 272A(1)(d)

Considering the totality of facts and circumstances, we are of the view that there was a reasonable cause for non-compliance to the notices by the P a g e | 4 ITA No. 4305/Mum/2025 Ay 2018-19 Vimal Pukhraj Jain assessee. The assessee’s explanation is backed by requisite documentary