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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

Devgiri Kalyan Ashram, Jalgaon vs. Commissioner of Income Tax (Exemptions), Pune

In the result, the appeal of assessee is treated as allowed for statistical purposes

ITA 1/PUN/2025[Not Applicable]Status: DisposedITAT Pune29 Aug 2025

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1/Pun/2025 Devgiri Kalyan Ashram, Vs. Cit, Exemption, Pune. Godai Balirampeth, Station Road, Jalgaon- 425001. Pan : Aadtd8830A Appellant Respondent Assessee By Shri Avinash Gundiyal (Virtual) : Revenue By : Shri Amol Khairnar Date Of Hearing : 28.08.2025 Date Of Pronouncement : 29.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.10.2024 Passed By Ld. Cit, Exemption, Pune Rejecting The Application For Registration U/S 80G(5) Of The It Act. 2. Facts Of The Case, In Brief, Are, That The Assessee Filed Application For Registration In Form No.10Ab Under Clause (Iii) Of First Proviso To Sub-Section (5) Of Section 80G Of The It Act On 18.05.2024. With A View To Verify The Genuineness Of Activities Of The Assessee & Fulfillment Of Conditions Laid Down In Clauses (I)

For Respondent: Shri Amol Khairnar
Section 12ASection 80GSection 80G(5)

make its submissions before the Ld. CIT(E) on the appointed date without seeking any adjournment under any pretext unless required for a reasonable cause, failing which the Ld. CIT(E) shall be at liberty to pass appropriate order as per law. We hold and direct accordingly. The ground raised

Venket Raman Narlwar, Throughout L/H Dr. Pratima Raman, Katni vs. Income Tax Officer -2, Katni

In the result, the appeal of the assessee is allowed

ITA 54/JAB/2025[2011-12]Status: DisposedITAT Jabalpur28 Aug 2025AY 2011-12

Bench: Shri Anadee Nath Misshradr. Pratima Raman (L/H Of V. Income Tax Officer-2 Venket Raman Narlwar Aayakar Bhawan, Sahkarita Maryadit) Jhinjhari, Katni-483501. Venket Building Lalita Bhawan, Sawarkar Ward, Katni-483501. Pan:Abhpn5492K (Appellant) (Respondent) Appellant By: Shri Dhiraj Ghai, Ca Respondent By: Shri N. M. Prasad, Sr. Dr-1 O R D E R (A) The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac)- Delhi, Dated 12.02.2025 Which In Turn Arose From The Penalty Order Passed Under Section 271(1)(B) Of The Income Tax Act, 1961 (“Act”, For Short) For The Assessment Year 2011-12. The Grounds Of Appeal Of The Assessee Are As Under: -

For Appellant: Shri Dhiraj Ghai, CAFor Respondent: Shri N. M. Prasad, Sr. DR-1
Section 143(3)Section 271(1)(b)Section 273B

Assessing Officer without providing reasonable opportunity to the assessee. Further, there is no material on record to show that the penalty is without “reasonable cause” within the meaning of Section 273B of the Act. Thus, in the facts and circumstances of the present case, it is found that neither ... assessee, nor the Assessing Officer has himself brought materials on record to establish that the assessee failed to comply with the aforesaid notice without “reasonable cause”. Further, on perusal of record, it is found in the facts and circumstances of this case, that the Assessing Officer has failed to make