A single sentence that overrides a long list of penalty provisions — sections 441, 442, 446, 448 to 463, 465(1)(c), 465(1)(d), 465(2), 466, 467 and 468 — and bars any penalty on a person or assessee for a failure referred to in those provisions if he proves that there was reasonable cause for the failure. Section 447 was in the list until Act No. 4 of 2026 omitted it with effect from 1 April 2026, so the defence is no longer available for that section.
Why it is there
It gives a single general defence across the penalty chapter, so that failures which are excusable do not attract penalty, while placing the burden of proving reasonable cause squarely on the person charged.
Who it applies to
A person or assessee facing penalty under any of the listed provisions
The authority imposing penalty under those provisions
The figures, and what each one turns on
Read the condition in the same row. A figure quoted without it is a wrong answer with a citation attached.
What
Figure
The condition on it
Where
Provisions covered by the reasonable cause defence
Section 447 was omitted from this list by Act No. 4 of 2026 with effect from 1 April 2026
S.470
What this means in practice
The defence is not automatic — the section requires that the person 'proves' reasonable cause, so it has to be raised and evidenced in the penalty proceedings rather than assumed. It works only for the sections named, so check the list before relying on it: a penalty imposed under a provision not listed, including section 439, is outside it entirely. From 1 April 2026 section 447 has been taken out of the list, so reasonable cause is no longer an answer to a penalty under that section.
An example
Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.
A company faces penalty under section 457 — 2% of the value of the transaction — for failing to furnish a document required by section 171(2), and proves in the penalty proceedings that there was reasonable cause for the failure. Section 457 is on the list in section 470, so no penalty shall be imposed at all: the relief is complete, not a reduction. But the defence has to be proved by the person and not found for him, and it reaches only the enumerated provisions — a penalty under section 439 is outside the list altogether, and from 1 April 2026 so is section 447, the words “or 447” having been omitted by Act No. 4 of 2026.
Where you meet this section
In the reply to a penalty show-cause notice and in the penalty proceedings before the authority imposing it, and again in an appeal against a penalty order. The section names no form and no authority; what it asks for is evidence of the cause, and a check that the provision you are being penalised under is actually on its list.
The words themselves
no penalty shall be imposed on a person or assessee for any failure referred to in the said provisions, if he proves that there was reasonable cause for the said failure
s.470, Income-tax Act, 2025.
What people get wrong
Assuming section 447 is still covered. Act No. 4 of 2026 omitted 'or 447' from the list with effect from 1 April 2026.
Treating this as a general defence to every penalty in the Act. It applies only to the provisions enumerated in the section — notably not to section 439.
Expecting the authority to find reasonable cause on its own. The section requires the person to prove it.
What this replaced
The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.
271DA - Penalty for failure to comply with provisions of section 269ST
271DB - Penalty for failure to comply with provisions of section 269SU
A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.
Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 470. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.
ADIT (Investigation) v Kum. A.B. ShanthiSupreme CourtHelps departmenttagged s.273B You took a cash loan and now face penalty equal to the whole amount. Is there any relief?
RBANMS Educational Institution v B. GunashekarSupreme CourtHelps departmenttagged s.271DA The section 269ST penalty falls on the person who receives the cash. If I am the buyer paying cash for property, am I exposed at all?
Chavakkad Service Co-operative Bank v ITOHigh CourtHelps taxpayertagged s.273B Our audit report was late because the statutory auditor was late. Can the officer still levy the s.271B penalty?
JCIT v Ganesh AgarwalHigh CourtCuts both waystagged s.271DA The Assessing Officer referred my section 269ST case to the Joint Commissioner months ago and the show cause notice has only just come. When does the…
PCIT v Shree Madhi Surali VibhagHigh CourtHelps taxpayertagged s.273B Our co-operative credit society took and repaid cash from its members and the appellate authorities deleted the 271D and 271E penalties on reasonable…
Sandeep Kaur Gill v Union of IndiaHigh CourtHelps taxpayertagged s.273B The financier insisted on cash. Can they penalise me under 271E for repaying the loan in cash?
DCIT v Umiya Co-operative Credit Society LtdITATHelps taxpayertagged s.273B Our credit society takes deposits and repays loans in cash to members. Can the department levy 271D and 271E on the whole amount?
Delta Farm Services v ITOITATHelps taxpayertagged s.271DA I received cash of more than Rs. 2 lakh from farmer-buyers against genuine, fully accounted sales in the first year of section 269ST. Can a section…
Sanmathi Ambanna v Jt CITITATHelps taxpayertagged s.273B I took a cash loan from my father-in-law. Can they levy 271D on a genuine family transaction?
CBDT Circular 22/2017CBDTHelps taxpayertagged s.271DA We take loan repayments in cash instalments. Do the instalments add up against the two lakh limit?
CBDT Circular 32/2019CBDTHelps departmenttagged s.271DB My turnover crossed Rs. 50 crore. Must I offer upi and RuPay, and what does it cost me if I don't?
What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.