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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

Nagendra Singh, Kasganj vs. Income Tax Officer, Ward-4(3)(3), Kasganj

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

ITA 234/AGR/2025[2017-18]Status: DisposedITAT Agra21 Aug 2025AY 2017-18

Bench: Shri S.Rifaur Rahmannagendra Singh, Vs. Ito, Ward 4(3)(3), House No.115, Goraha, Kasganj, Kasganj. Kanshiram Nagar – 207 123 (Uttar Pradesh). (Pan : Dqzps5814Q) (Appellant) (Respondent) Assessee By : Shri Anurag Sinha, Advocate Revenue By : Shri Anil Kumar, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 21.08.2025 O R D E R 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Jcit(A)”, For Short] Dated 27.02.2025 For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, During Assessment Proceedings, The Assessing Officer Observed That Assessee Has Deposited Cash Amounting To Rs.15,00,000/- Into His Bank Account Maintained With Gramin Bank Of Aryavart, Goraha, Kasganj & Another Rs.2,50,000/- To Another Account Maintained With Ubi, Railway Road, Kasganj During The Demonetization Period. Since The Assessee Has Not Filed Any Return Of Income, Notice U/S 142(1) Of The Income-Tax Act, 1961 (For Short ‘The Act’) Was Issued To The Assessee To File The Return Of Income For The Ay 2017-18 On Or Before 31.03.2018. The Assessee Has Not Filed Any Return Of Income. A Show-

For Appellant: Shri Anurag Sinha, AdvocateFor Respondent: Shri Anil Kumar, Sr. DR
Section 115BSection 142(1)Section 144Section 69A

Rs.15,00,000/- was accepted, however for the additional deposit of unexplained cash to the tune of Rs.2,50,000/- was treated as unexplained money u/s 69A of the Act. 3. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi and filed detailed submissions, however

Kalai Vani Rajan, Salem vs. ITO, Ward-1(6), Salem

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

ITA 774/CHNY/2025[2012-13]Status: DisposedITAT Chennai20 Aug 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.774/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 Kalai Vani Rajan, Vs. The Income Tax Officer, C-1, Sai Krishna Apartment, Ward I(6), Brindavanan Road, 3Rd Cross, Salem. Fairlands S.O., Salem 636 016 [Pan:Avxpk9339C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 29.07.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against Order Dated 27.01.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2012-13. 2. The Ld. Ar Shri S. Sridhar, Advocate Submits That The Assessee Is Not Interested To Prosecute Legal Grounds Raised In Ground No. 4 & 5 & 2

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 69A

assessee raised ground Nos. 6 to 9 challenging the action of the ld. CIT(A) in confirming the addition on account of unexplained money under section 69A of the Income Tax Act, 1961 [“Act” in short]. 4. Brie facts relating to the case are that the assessee is an individual

Narayanan, Chromepet vs. Income Tax Officer, Chennai

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

ITA 695/CHNY/2025[2018-2019]Status: DisposedITAT Chennai20 Aug 2025AY 2018-2019

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.695/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Narayanan, Vs. The Income Tax Officer, F-1, 37/60, Guru Balaji Apts, International Taxation Ward 2(1), First Main Road, New Colony, Chennai. Chromepet, Chennai 600 044. [Pan:Ackpn6481A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 24.07.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 06.01.2025 Passed By The Income Tax Officer, International Taxation Ward 2(1), Chennai Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. When The Appeal Was Taken Up For Hearing On 24.07.2025, We Find No Representation On Behalf Of The Assessee. However, We Find Paper

For Appellant: NoneFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 142(1)Section 143(2)Section 144C(1)Section 147Section 148Section 69

respond. Therefore, in absence of any details, the Assessing Officer treated the amount of remittances to the tune of ₹.2,59,49,000/- as unexplained money under section 69 r.w.s. 115BBE of the Act. Further, the Assessing Officer noted that the assessee sold an immovable property