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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

Rajesh Baburao Shinde, Parbhani vs. ITO, Ward- Hingoli, Hingoli

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

ITA 781/PUN/2025[2015-16]Status: DisposedITAT Pune12 Aug 2025AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.781/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Rajesh Baburao Shinde, Vs. Assessment Unit, Income Sayala Khating, Tq. Dist. Tax Department, Nfac, Parbhani- 431402. Delhi. Pan : Czcps6546Q Appellant Respondent Assessee By : Shri Shubham N. Rathi Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 22.07.2025 Date Of Pronouncement 12.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Akhilesh Srivastva
Section 142(1)Section 145Section 148Section 148ASection 151ASection 69A

show cause notice dated 14.05.2023. Accordingly the Assessing Officer treated the amount of Rs.51,11,900/- deposited in the impugned account as unexplained money u/s 69A r.w.s. 115BBE of the IT Act and added the same to the total income of the assessee. Vide order dated 23.05.2023 the Assessing Officer ... income returned by the assessee at Rs.2,34,760/- in response to notice u/s 148 of the IT Act. The above assessed income includes unexplained money of Rs.51,11,900/- u/s 69A of the IT Act. 5. Against the above assessment order, assessee preferred an appeal before

Hussain Theparambil Faisal, Thrissur vs. ITO, Ward 2(1), Thrissur

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 520/COCH/2025[2017-18]Status: DisposedITAT Cochin11 Aug 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Hussain Theparambil Faizal .......... Appellant Theparambil, Chalingadu, Kaipamangalam Thrissur 680681 [Pan: Acvpf5761G] Vs. The Income Tax Officer, Wd-2(1), Thrissur .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.08.2025 Date Of Pronouncement: 11.08.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-1, Hyderabad [Cit(A)] Dated 23.12.2024 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That Appellant Is An Individual. No Return Of Income Under The Provisions Of Section 139(1) Of The The Income Tax Act, 1961 (The Act) Was Filed By The Appellant For Ay 2017-18. However, Based On The Information That The Appellant Made Cash Deposit In Specified Bank Notes (Sbn) During Demonetisation Period, The Ito, Ward 2(1), Thrissur (Hereinafter Called "The Ao") Issued A Notice U/S. 142(1) Of The Act Calling Upon The Appellant To 2 Hussain Theparambil Faizal File Return Of Income. The Appellant Neither Complied With The Notice U/S. 142(1) Nor The Notice U/S. 143(2) Of The Act. In The Circumstances, The Ao Proceeded With Making Best Judgement Assessment By Making Addition Of The Cash Deposits Made During The Demonetisation Period As Unexplained Money Of The Appellant Vide Order Dated 29.12.2019 Passed U/S. 144 Of The Act.

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 142(1)Section 143(2)Section 144

circumstances, the AO proceeded with making best judgement assessment by making addition of the cash deposits made during the demonetisation period as unexplained money of the appellant vide order dated 29.12.2019 passed u/s. 144 of the Act. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide