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“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

Sucram Pharmaceuticals Pvt. Ltd., Chennai vs. ITO, Ncw-6(4), Chennai

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

ITA 1022/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Aug 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1022/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Sucram Pharmaceuticals Private Vs. The Income Tax Officer, Limited, H-37-J, 2Nd Floor, Non Corporate Ward 6(4), Manthoppu Colony, Ashok Nagar, Chennai. Chennai 600 083. [Pan:Aakcs2196J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. Lekha, Ca ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.07.2025 घोषणा की तारीख /Date Of Pronouncement : 22.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. Ground No.1 Raised By The Assessee Is General In Nature & Requires No Adjudication.

For Appellant: Ms. Lekha, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 133(6)Section 142(1)(ii)Section 69

assessee failed to prove with any concrete evidence and document, the Assessing Officer disallowed ₹.1,15,000/- as unexplained money under section 69 of the Act. The ld. CIT(A) confirmed the above addition made by the Assessing Officer. 10. The ld. AR submits that the cash in hand

Kishorkumar Lakhaji Prajapati, Mumbai vs. Income Tax Officer 32(2)(2), Mumbai

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

ITA 3688/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Aug 2025AY 2017-18

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3688/Mum/2025 (नििाारण वर्ा / Assessment Year: 2017-18) Kishorkumar Lakhaji V/S. Income Tax Officer- Prajapati बिाम 32(2)(2) A/101, Krishna Avenue, Room No. 716, 7Th Floor, Shree Krishna Nagar, Kautilya Bhavan, C-41 To Mumbai 400006 C043, G Block, Bkc, Bandra East, Mumbai 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaipp5132E Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri K. Shivaram Sr. Adv & Ms. Neelam Jadhav राजस्व की ओर से /Revenue By: Shri Asif Karmali Sr. Dr

For Appellant: Shri K. Shivaram Sr. Adv & MsFor Respondent: Shri Asif Karmali Sr. DR
Section 115BSection 144Section 250Section 69A

17/08/2019. P a g e | 2 ITA No 3688/Mum/2025 AY 2017-18 Kirshorkumar Lakhaji Prajapati II Addition of Rs.11.50,000/- u/s.69A as Unexplained Money 2. The Learned National Faceless Appeal Centre (NFAC) has erred in confirming the addition of Rs.11,50,000/- u/s. 69A of the Income ... unexplained money without appreciating that amount deposited in the bank account was on account sale transactions, which are properly recorded in the books of account and shown as cash in hand in the books of account wherein the appellant has maintained day to day stock transaction register, hence addition