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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

Ranjan Kumar Sharma, East Champaran vs. Assessment Unit Ptn-W-(27)(2) Income Tax Department, Delhi

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

ITA 64/PAT/2025[2018-19]Status: DisposedITAT Patna02 Sept 2025AY 2018-19

Bench: S/Shri George Mathan & Rajesh Kumarassessment Year : 2018-19 Ranjan Kumar Sharma, S/O. Vs. Assessment Unit, Income Tax Shyama Sharma Shyampur, Department, Adapur, East Champaran- 845301 Pan/Gir No. Drpps 9579 R (Appellant) .. ( Respondent) Assessee By : None (Adjn.Petition) Revenue By : Shri Ashwani Kumar, Sr. Dr Date Of Hearing : 02/09/2025 Date Of Pronouncement : 02/09/2025 O R D E R Per Bench The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nafc), New Delhi Nfac), Delhi Dated 17.12.2024 In Appeal No.Nfac/2017-18/10263675 Passed For Assessment Year 2018-19. 2. None Appeared On Behalf Of The Assessee. However, An Adjournment Petition Has Been Filed By The Assessee To Adjourn The Matter To 4.9.2025. Considering The Facts Of The Case, We Reject The Adjournment Petition & Proceed To Decide The Appeal Exparte After Hearing Ld Sr Dr.

For Appellant: None (Adjn.petition)For Respondent: Shri Ashwani Kumar, Sr. DR

delay of 85 days and dismissed the appeal of the assessee on account of delay in filing the appeal. The assessee has given reasonable cause for filing the appeal delay of 85 days. It is also noticed that the assessee has not represented before the ld CIT(A). This being

Mata Balwinder Kaur Charitable Foundation, Ludhiana vs. DCIT, Central Circle-2, Ludhiana

The appeal stand allowed for statistical purposes

ITA 338/CHANDI/2025[2025-26]Status: DisposedITAT Chandigarh02 Sept 2025AY 2025-26

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.338/Chandi/2025 Mata Balwinder Kaur Charitable Foundation Cit (Exemptions) बनाम/ 5Th Floor, Grand Walk Mall Chandigarh Opp. Gurudev Hospital, Ferozepur Road Vs. Ludhiana - 142021 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocm-4786-E (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ" की ओर से / Appellant By : Shri Rajesh Mehru (Ca) -Ld. Ar ""थ" की ओर से / Respondent By : Shri Arvind Kumar (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 26-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-09-2025

For Appellant: Shri Rajesh Mehru (CA) -Ld. ARFor Respondent: Shri Arvind Kumar (CIT) – Ld. DR
Section 12A(1)(ac)

referred to amendment made by Finance Act, 2024 which empowers the PCIT / CIT to condone such delays provided there is a reasonable cause for the delay. The said amendment has come into effect from 01-10-2024. A proviso has been added after sub- clause (vi) of Sec.12A ... filed beyond the time allowed in sub- clauses (i) to (vi), the Principal Commissioner or Commissioner may, if he considers that there is a reasonable cause for delay in filing the application, condone such delay and such application shall be deemed to have been filed within time

Ravinder Singh, Ludhiana vs. ITO, Ward-3(5), Ludhiana

The appeal stand partly allowed

ITA 320/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh02 Sept 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.320/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Ravinder Singh Ito-Ward-3(5) (Prop. M/S Nirmal Fashions) Ludhiana. बनाम/ Beas Hosiery Complex, Kailash Nagar Road, Vs. Opp. Radha Swami Satsang Bhawan, Ludhiana-141007. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Brzps-2060-R (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Amarjit Kamboj (Ca) (Virtual Mode) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing : 25-08-2025 घोषणा की तारीख / Date Of Pronouncement : 02-09-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2017-18 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 14-01-2025 Confirming Penalty Of Rs.50,000/- As Levied By Ld. Assessing Officer [Ao] U/S. 272(1)(D) R.W.S. 274 Of The Act Vide Order

For Appellant: Sh. Amarjit Kamboj (CA) (Virtual Mode) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 142(1)Section 144Section 272(1)(d)

notices. The Ld. AO imposed penalty of Rs.10,000/- for each of the five defaults on the ground that the assessee failed to establish reasonable cause for non-appearances. The Ld. CIT(A) confirmed the same on the ground that the notices were received on email id of assessee ... Chartered Accountant and there was no reasonable cause. Aggrieved, the assessee is in further appeal before us. 3. The assessee, indeed, has defaulted in complying with identical notices as issued by Ld. AO u/s 142(1) from time to time. However, it could be seen that penalty has been levied