← All Phrases

“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull
87 ITR 349 · 1973 · Supreme Court
525
citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT
107 ITR 938 · 1977 · Supreme Court
477
citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.
208 ITR 465 · 1994 · High Court
427
citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT
172 ITR 250 · 1988 · Supreme Court
340
citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Upkar Mani, Delhi vs. ACIT CC-8, Jhandewalan

In the result, the appeal of the assessee is dismissed

ITA 3022/DEL/2023[2018-19]Status: DisposedITAT Delhi02 Sept 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year 2018-19]

Section 132Section 153CSection 153DSection 250Section 69A

erred on facts and in law in sustaining the addition of Rs.32,62,500/- made by the Ld. Assessing Officer on account of unexplained money under section 69A of the Act without appreciating the facts of the case and relying solely upon dumb documents. 6. That the impugned ... Sushant Lok, Phase-1, Gurugram, therefore, the part of sale consideration received in cash amounting to Rs.32,62,500/- attributable to him was unexplained money in the hands of the assessee. The Assessing Officer also noted that moreover the cash receipt of Rs.32,62,500/- as part of sale consideration

Ranar Agrochem Limited, Parawada vs. Deputy Commissioner of Income Tax, Visakhapatnam

ITA 288/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam31 Aug 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

For Appellant: Shri M. Madhusudan, CAFor Respondent: Sri Jenardhanan V, CIT-DR
Section 143(2)Section 143(3)Section 250Section 36(1)Section 36(1)(va)Section 40Section 68

Ranar Agrochem Limited vs. DCIT that the admission of the subject additional evidence will lead to a loss to the Government exchequer, wherein an unexplained money routed in the garb of unverified loan transactions would go untaxed. 9. We have thoughtfully considered the contentions of the Learned Authorized Representatives

Shokat Ali, Delhi vs. AO, Ward 60(7)/ Assessed by Ward 60(5), Delhi

In the result, appeal of the assessee is partly allowed

ITA 7001/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Aug 2026AY 2017-18

Bench: Shri Vikas Awasthyआअसं.7001/धिल्ली/2025 (नि.व. 2017-18) Shokat Ali, D-54, Gali No. 2, Noor Aillahi, North Ghonda, New Delhi 110053 ...... अपीलार्थी/Appellant Pan: Adgpa-3353-H बिाम Vs. Assessing Officer, Ward-60(7), ..... प्रनिवादी/Respondent Assessed By Ward 60(5), Vikas Bhawan, Delhi 110002 अपीलार्थी द्वारा/Appellant By : None प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 02/01/2026 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: NoneFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115BSection 143(2)Section 69A

explanation and supporting documentary evidence regarding the source of such cash deposits. The AO treated the cash deposits of Rs.30,01,000/- as unexplained money u/s.69A of the Act and added the same to the total income of the assessee. The AO also invoked the provisions of section 115BBE

Revelation Unique Retail and Marketing Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-3, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 1036/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Aug 2026AY 2020-21

Bench: Shri Vimal Kumarshri Sanjay Awasthl

For Appellant: Sh. Pranshu Goel, CA & Aditya Gupta, AdvFor Respondent: Sh. Robin Rawal, CIT- DR
Section 115BSection 127Section 132Section 142(1)Section 153Section 153CSection 234Section 234BSection 250Section 272A(1)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E”, NEW DELHI BEFORE SHRI VIMAL KUMAR, JUDICIAL MEMBER SHRI SANJAY AWASTHL

Yamaappa Bagayi, Gokak vs. Income Tax Officer, Ward - 1, Gokak

In the result, Stay Application and appeal filed by the assessee are dismissed

ITA 17/PAN/2023[2017-18]Status: DisposedITAT Panaji18 Aug 2026AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Saidappa Gadadi, ARFor Respondent: Shri N. Shrikanth, DR
Section 142(1)Section 40A(3)Section 69A

accept the assessee’s contention and added the amount of Rs.54,26,000/- to the total income of the assessee as unexplained money u/sec. 69A r.w.s. 115BBE of the Act. The AO further, on perusal of the books of account produced by the assessee, held that assessee had made payments

Veeyemar & Co., Calicut vs. ITO, Ward 1(3), Kozhikode

In the result, the appeal filed by the assessee is dismissed

ITA 370/COCH/2025[2017-18]Status: DisposedITAT Cochin10 Aug 2026AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Veeyemar & Co. .......... Appellant 12/1059, Big Bazaar, Calicut-673001, Kerala. [Pan: Aacfv 7568 E] Vs. Ito, National Facells Centre, .......... Respondent Delhi.

For Appellant: NoneFor Respondent: Smt. Leena Lal, Sr. DR
Section 133(6)Section 147Section 148

cannot be accepted. Therefore, the AO was justified in making the addition and added the same to the total income of the assessee as unexplained money. 3 Meat Products of India Ltd. I do not find any illegality or perversity in the findings of the lower authorities. Accordingly, I find

Shashi Bala, Ballabgarh vs. ITO Ward 4(1)(1), Aligarh

In the result, assessee’s appeal is dismissed

ITA 426/AGR/2025[2016-17]Status: DisposedITAT Agra04 Aug 2026AY 2016-17

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2016-17

Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 251(1)(a)Section 69Section 69A

unexplained on behalf of the assessee and added by the Assessing Officer to the income of the assessee u/s. 69A of the Act as unexplained money. The Assessing Officer also noticed that the assessee had made payment of Rs.5,17,00,000/- for purchase of properties, out of which payments

Rajeswaramma Duvvuru, Nellore vs. ITO., Ward-1, Gudur

ITA 227/HYD/2025[2017-18]Status: DisposedITAT Hyderabad08 Jul 2026AY 2017-18

Bench: Us:

Section 143(2)Section 147Section 148Section 69A

Assessing Officer/CIT(A) is erroneous, is contrary to law, principles of natural justice and opposed to the facts and circumstances of the case. Unexplained Money u/s 69A – Loan advanced to Agriculturist – Rs. 15,50,000/- (ii). The Learned AO/CIT(A) ought to have appreciated the Appellant had already explained ... explanation regarding the source of the cash loan of Rs. 16.50 lacs (supra), therefore, the A.O was constrained to treat the same as her unexplained money under Section 69A of the Act. Further, as the assessee during the assessment proceedings, despite specific directions had failed to lead any evidence

Mohammad Amin, Guna vs. National Faceless Assessment Centre, Delhi

ITA 270/AGR/2024[2017-18]Status: DisposedITAT Agra21 May 2026AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: NoneFor Respondent: Sh. Shailener Shrivastava, Sr. DR
Section 115BSection 147Section 251(1)(a)Section 69A

lower appellate discussion(s) not only reversing assessment findings assessing his cash deposits; involving varying sums, as business income in capital trade etc. as unexplained money u/s 69A of the Act but also his consequential directions that the same ought to be assessed u/s 115BBE

Mohammad Amin, Guna vs. National Faceless Assessment Centre, Delhi

ITA 269/AGR/2024[2015-16]Status: DisposedITAT Agra21 May 2026AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: NoneFor Respondent: Sh. Shailener Shrivastava, Sr. DR
Section 115BSection 147Section 251(1)(a)Section 69A

lower appellate discussion(s) not only reversing assessment findings assessing his cash deposits; involving varying sums, as business income in capital trade etc. as unexplained money u/s 69A of the Act but also his consequential directions that the same ought to be assessed u/s 115BBE

Seema Katar, Delhi vs. ITO Ward -49 (2), Delhi

In the result, assessee’s appeal is dismissed

ITA 5567/DEL/2025[2017-18]Status: DisposedITAT Delhi12 May 2026AY 2017-18

Bench: DELHI BENCH “SMC”: NEW DELHI Ms. MADHUMITA ROY (Judicial Member)

Section 143(3)Section 250Section 69A

justify the source of cash deposits amounting to Rs 28,00,000/-. Accordingly, the addition of Rs. 28,00,000/- u/s 69A as unexplained money is confirmed, and the respective ground of appeal is hereby dismissed.” 5. No supportive evidence explaining the source of cash deposits has been brought

Himanshu Daksheshkumar Katwala, Khambhat Anand vs. Income Tax Officer, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 199/AHD/2026[2017-2018]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2017-2018

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Hardik J Raval & Vivek D Rao, ARsFor Respondent: Shri Girish Parihar, Sr. DR
Section 115BSection 132Section 143(3)Section 147Section 69A

Relying on the investigation report, search findings and surrounding circumstances, the Assessing Officer held that the transactions of Rs. 29,81,262/- were the unexplained money in the nature of accommodation entries. Accordingly, the said amount was added to the income of the assessee under section 69A read with section

Abhishekbhai Ashokbhai Patel, Kadi vs. The ITO, Ward 1, Mehsana

In the result, the appeal of the assessee is partly allowed

ITA 1803/AHD/2025[2010-11]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Deepak, ARFor Respondent: Smt. Ananya Kulshresth, Sr. DR
Section 133(6)Section 144Section 147Section 69A

aggregating to Rs.12,27,000/-, the source of which remained unexplained. Accordingly, the said amount was added under section 69A of the Act as unexplained money. Further, interest income of Rs.65/- was also added. The Assessing Officer also made an addition of Rs. 46,590/- being profit from share transactions

Ambey Enterprises, Delhi vs. Assessing Officer, Delhi

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

ITA 5505/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarambey Enterprises Vs. Assessing Officer 30/54 A 1St Floor Gali Ward 58(1) No.8, Vishwas Nagar Delhi Shahdara, Delhi 110032 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abdfa 0570D Appellant .. Respondent

For Appellant: NoneFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 142(1)Section 144Section 250Section 68Section 69A

That the learned AO has erred in law by treating the amount credited before demonetization Rs. 11,56,92,274/- as unexplained money u/s 68 of the Income Tax Act, 1961 and making additions of Rs. 69,41,536.44 (being 6% of Rs. 11,56,92,274/-) to the total ... assessee. 3. That the learned AO has erred in law by treating the cash deposited during demonetization Rs. 11,59,850/- as unexplained money u/s 69A of the Income Tax Act, 1961 4. That on the facts and in the circumstances of the case

Yuvradhani Agro & Developers Pvt Ltd, Yavatmal vs. ITO Ward-1, Yavatmal

In the result, the appeal of the assessee is allowed

ITA 47/NAG/2026[2017-18]Status: DisposedITAT Nagpur26 Mar 2026AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.47/Nag/2026 Assessment Year : 2017-18 Yuvradhani Agro & Developers Vs. Income Tax Officer, Pvt Ltd. Ward-1, Yavatmal G.No 68 Ralegaon, Yavatmal 445402, Maharashtra Pan: Aaacy5622R Appellant Respondent

For Appellant: Ms.Alfiya RozieFor Respondent: Shri Surjit Kumar Saha
Section 144Section 148Section 69A

resulting into passing of 2 Yuvradhani Agro & Developers Pvt Ltd. Best Judgment assessment and addition of Rs.25.00 lakh made u/s.69A of the Act towards unexplained money. Thereafter assessee preferred appeal before ld.CIT(A) which was delayed by 265 days. Majority of the delay pertains to covid-19 pandemic outbreak period

Pradeep Sharda, Dehradun vs. ACIT, Dehradun

In the result, the appeal of the assessee is allowed

ITA 223/DDN/2025[2017-18]Status: DisposedITAT Dehradun25 Mar 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2017-18] Pradeep Sharda Vs Acit 7, Inder Road, Dehradun Circle-1(2)(1) Uttarakhand -248001 Dehradun Pan-Adwps5692K Uttarakhand Appellant Respondent Appellant By Shri Anil Jain, Adv. Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 12.03.2026 Date Of Pronouncement 25.03.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 24.09.2025 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-1, Nashik [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10344/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 01.11.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Practicing Doctor & E-Filed His Return Of Income, Declaring Total Income Of Inr 2,16,70,906/- On 30.10.2017. The Assessment Was Completed U/S 143(3) Of The Act By Making Additions Of Inr 15,84,870/- Comprising Of The Disallowance U/S 40(A)(Ia) Of The Act Of Inr 5,05,195/- & Treating The Agricultural Income Of Inr 6,25,000/- As Unexplained Money U/S 69A Of The Act & Of Inr 4,54,675/- As The Addition U/S 68 Of The Act On Account Of Cash Credit.

Section 143(3)Section 250Section 40Section 68Section 69A

disallowance u/s 40(a)(ia) of the Act of INR 5,05,195/- and treating the agricultural income of INR 6,25,000/- as unexplained money u/s 69A of the Act and of INR 4,54,675/- as the addition u/s 68 of the Act on account of cash credit ... Ground of appeal No.3 raised by the assessee is with respect to addition of INR 6,25,000/- treated as agricultural income as unexplained money. 8. Before us, Ld.AR for the assessee submits that assessee’s father, Shri Satish Chandra Sharda owned large area of land where the Apples

Ranjana Devi, Maur Mandi vs. Income Tax Officer Ward-1(1), Bathinda

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

ITA 410/ASR/2025[2017-18]Status: DisposedITAT Amritsar20 Mar 2026AY 2017-18

Bench: Dr. Dipak P. Ripote & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 410/Asr/2025 Assessment Year: 2017-18 Ranjana Devi, C/O Jishu Trading Vs. Ito, Ward-1(1), Co. Maur Mandi, Punjab. Bathinda. [Pan:-Alzpd4607L] (Appellant) (Respondent) None. Appellant By Respondent By Sh. Charan Dass, Sr. Dr.

Section 133(6)Section 142(1)Section 143(3)Section 250Section 263Section 69A

Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi further gravely erred in upholding the addition of Rs. 11,50,000/- as alleged unexplained money on account of cash deposited in the bank account by resort to provisions of Section 69A of the Act.” Statement of Facts 5. Statement

Rajesh Kumar Tiwari, Raipur vs. Income Tax Officer, Ward-2(2), Raipur

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

ITA 844/RPR/2025[2012-13]Status: DisposedITAT Raipur20 Mar 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 844/Rpr/2025 (िनधा"रण वष" Assessment Year: 2012-13) Rajesh Kumar Tiwari, Shiv Mandir Gali, Vs Income Tax Officer, Ward-2(2), Gali No.9, Basant Vihar, Gondwara, Raipur, Income Tax Office, Raipur, Chhattisgarh-493221 Central Revenue Building, Civil Lines, Raipur, C.G. - 492001 Pan: Ajgpt8095F (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None (Adjournment Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 17/03/2026 घोषणा की तारीख / Date Of : 20/03/2026 Pronouncement

For Appellant: None (Adjournment filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 131Section 151Section 250Section 69A

been considered as income of the Appellant for relevant AY 2012-13 and added to his total income as unexplained money u/s. 69A of the Income Tax Act, 1961, whereas Rs. 59,76,720/- credited in Appellant's bank account in FY 2012-13 and relates ... back in the returned income. Further, the Ld. AO also made an addition of Rs.74,76,720/- under section 69A of the Act as unexplained money as under: “7. In respect of other issues regarding the payments receipt from Hind Energy and Coal Benefication

Aneemoni Naga Raju, Hyderabad vs. ITO, Ward- 8(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical

ITA 2074/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad20 Mar 2026AY 2020-2021
Section 1Section 142(1)Section 147Section 148Section 249(4)(b)Section 69A

information and explanations and submissions, and violation of natural justice. 3. The Id. AO erred in making addition of Rs.1,11,41,476/- as unexplained money u/s 69A (25,00,000+47,00,000+ 20,77,000+18,16,631+48,350), by treating all bank credits in the appellant ... savings account (No.236401500040) as unexplained money under Section 69A of the Act, thereby classifying the entire amount as income from other sources. 4. With regard to the credit of ₹25,00,000/-, the appellant had duly explained that it was a hand loan extended by his friend, Mr. Mahipal Reddy

Suresh Nammi, Hyderabad vs. Income Tax Officer, Ward-8(3), Hyderabad

In the result, appeal of the assessee is dismissed in terms of our aforesaid observations

ITA 1620/HYD/2025[2017-18]Status: DisposedITAT Hyderabad20 Mar 2026AY 2017-18

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA, HON’BLE (Accountant Member)

Section 139Section 142(1)Section 144Section 69A

source of the aforesaid credit entries/cash deposits, therefore, the AO held the entire amount as having been sourced out of the assessee’s unexplained money under section 69A of the Act. Accordingly, the AO vide his order passed under section 144 of the Act, dated 04/12/2019 determined the income

unexplained money — 5,888 case laws | BharatTax