← 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

Sunku Surendra, Nellore vs. ITO., Ward-1, Nellore

In the result, appeal filed by the assessee is dismissed being barred by limitation

ITA 1026/HYD/2025[2015-16]Status: DisposedITAT Hyderabad04 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1026/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Sunku Surendra Vs. Income Tax Officer Nellore Ward – 1 Pan:Aysps4353G Nellore (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Vvsc Muralidhar Rao, Advocate राज" व "ारा/Revenue By:: Shri Suresh Babu Kn, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 25/08/2025 घोषणा की तारीख/Pronouncement: 04/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal By The Assessee Is Directed Against The Order Dated 28/02/2019 Of The Learned Cit (A)-Tirupati, For The A.Y.2015-16. 2. There Is A Delay Of 2235 Days In Filing The Present Appeal. The Assessee Has Filed A Petition For Condonation Of Delay Which Is Supported By An Affidavit. The Learned Counsel For The Assessee Has Submitted That The Assessee Was Suffering From Page 1 Of 9

For Appellant: Shri VVSC Muralidhar RaoFor Respondent: : Shri Suresh Babu KN, Sr.AR

other hand, the learned DR has objected to the condonation of delay and submitted that the assessee has not explained any reasonable cause for such an inordinate delay in filing the appeal. Further, the assessee admitted the discrepancies in the income and conceded to the addition made by the Assessing ... underhand way by filing the appeal beleatedly. Therefore, for taking a lenient view to interpret the expression “sufficient cause” there must be a reasonable cause to justify the delay particularly, when there is an inordinate delay. We cannot overlook the apparent unacceptable and unsatisfactory reasons explained by the assessee when

The Chimna Agri. Ser Vice Society Ltd., Punjab vs. Jao Income Tax Officer, ITO, Ward-1, Jagraon, Punjab

In the result, both the appeals filed by the Assessee are allowed for statistical purposes

ITA 423/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh03 Sept 2025AY 2020-2021

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 422/Chd/2025 "नधा"रण वष" / Assessment Year : 2020-21 & आयकर अपील सं./ Ita No. 423/Chd/2025 "नधा"रण वष" / Assessment Year : 2020-21 The Chimna Co-Op. Agri. Jao. बनाम Service Society Ltd., Income Tax Officer Vpo Chimna, Jagraon, Ward 1, Vs. Ludhiana. 141011 Jagraon "थायी लेखा सं./Pan No. Aaaat4706D अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Shri. Kushal Chopra, C.A. (Virtual) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 30-07-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 03.09-2025 आदेश/Order

For Appellant: Shri. Kushal Chopra, C.A. (virtual)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 250Section 270ASection 80PSection 80P(2)(d)

hearing and, as such, the appellant was 3 423-424-Chd-2025 The Chimna Agri Service Society Ltd., Ludhiana prevented by sufficient and reasonable cause for filing any submissions before the Ld. CIT(A). 4. That notwithstanding the above grounds of appeal, the addition made by the Ld. Assessing Officer ... counsel for his Income Tax matters, who did not intimate him about the hearing and, as such, the appellant was prevented by sufficient and reasonable cause for filing any submissions before the Ld. CIT(A). 4. That notwithstanding the above grounds of appeal, the penalty as levied

The Chimna Co-Op Agri. Service Society Ltd., Punjab vs. Jao the Income Tax Officer Ward 1 Jagraon, Punjab

In the result, both the appeals filed by the Assessee are allowed for statistical purposes

ITA 422/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh03 Sept 2025AY 2020-2021

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 422/Chd/2025 "नधा"रण वष" / Assessment Year : 2020-21 & आयकर अपील सं./ Ita No. 423/Chd/2025 "नधा"रण वष" / Assessment Year : 2020-21 The Chimna Co-Op. Agri. Jao. बनाम Service Society Ltd., Income Tax Officer Vpo Chimna, Jagraon, Ward 1, Vs. Ludhiana. 141011 Jagraon "थायी लेखा सं./Pan No. Aaaat4706D अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Shri. Kushal Chopra, C.A. (Virtual) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 30-07-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 03.09-2025 आदेश/Order

For Appellant: Shri. Kushal Chopra, C.A. (virtual)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 250Section 270ASection 80PSection 80P(2)(d)

hearing and, as such, the appellant was 3 423-424-Chd-2025 The Chimna Agri Service Society Ltd., Ludhiana prevented by sufficient and reasonable cause for filing any submissions before the Ld. CIT(A). 4. That notwithstanding the above grounds of appeal, the addition made by the Ld. Assessing Officer ... counsel for his Income Tax matters, who did not intimate him about the hearing and, as such, the appellant was prevented by sufficient and reasonable cause for filing any submissions before the Ld. CIT(A). 4. That notwithstanding the above grounds of appeal, the penalty as levied