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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

Shivaji Vishnu Chavan, Pune vs. Uito Ward-5(4), Pune

In the result, appeal of the assessee is allowed

ITA 1143/PUN/2025[2011-12]Status: DisposedITAT Pune13 Aug 2025AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1143/Pun/2025 िनधा"रण वष" / Assessment Year: 2011-12 Shivaji Vishnu Chavan, V The Income Tax Officer, Gomukh, 92/2, Gangtok, S Ward-5(4), Pune. Narsapur, Pune – 411004. Maharashtra. Pan: Aaspc1061B Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Arvind Renge – Addl.Cit(Dr) Date Of Hearing 31/07/2025 Date Of Pronouncement 13/08/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Shivaji Vishnu Chavan In Form No.36 Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 31.05.2024 For The A.Y.2011-12 Emanating From Assessment Order U/S.147 R.W.S 144 Of The Income Tax Act, 1961 For A.Y.2011-12, Dated 12.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 250Section 274Section 50CSection 68

facts and in the circumstances of the case and in law, Ld.AO erred in making an addition of Rs.5,42,000/- u/s 68 - Unexplained Money, being sale of immovable property, without appreciating the fact that appellant is only the owner of 1/6th portion of such property and if the indexed ... Hence, assessee’s share of Rs.5,42,000 is treated as his income of the year under the head Income from capital gain and unexplained money u/s. 68 of the Act and brought to tax . Penalty proceedings u/s. 274 r.w.s. 271(l)(c ) of the Act has been initiated separately

K.P.Ramaswamy, Rasipuram vs. Income Tax Officer, Ward-2, Namakkal

In the result, appeal filed by the assessee is allowed

ITA 702/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Aug 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:702/Chny/2025 धनिाारण वर्ा / Assessment Year: 2017-18 K.P.Ramaswamy, The Income Tax Officer, 6-A, Building Society Road, Vs. Ward-2 No.5 Voc Nagar, Rasipuram Tk, Namakkal. Namakkal - 637 408. [Pan: Achpr-5024-Q] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Sri Krishna, C.A (Virtual) प्रत्यथी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit. सुनवाई की तारीख/Date Of Hearing : 26.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

For Appellant: Shri. Sri Krishna, C.A (Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(1)Section 143(2)Section 143(3)Section 69A

assessee, an amount of Rs.17,75,635/- was credited as agricultural income. hence the AO treated excess amount of Rs.4,75,635/- as unexplained money made an addition of Rs.14,87,000/- and Rs.4,75,635/- as unexplained money u/s.69A r.w.s.115BBE of the Act, passed an order u/s.143 ... passed order by treating cash deposit made during the demonetisation of Rs.14,87,000/- and an agricultural income of Rs.4,75,635/- as unexplained money u/s.69A of the Act. On appeal the ld.CIT(A) deleted the cash deposit of Rs.14.87 lakhs and confirmed the agricultural income as unexplained money u/s.69A