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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

Sunil Melathilveedu Nazarudeen, Oyoor vs. ITO Ward 3, Kollam

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

ITA 363/COCH/2025[2017-18]Status: DisposedITAT Cochin31 Jul 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2017-18 Sunil Melathilveedu Nazarudeen .......... Appellant Melathil Veedu, Payyacode, Oyoor, Kollam [Pan: Aefpn3764B] Vs. The Income Tax Officer, Wd-3, Kollam 691510.......... Respondent Appellant By: Shri R. Krishnan, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 13.06.2025 Date Of Pronouncement: 31.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 31.01.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income For Ay 2017-18 Was Filed By The Appellant Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). The Income Tax Officer, Ward-3, Kollam (Hereinafter Called "The Ao") Had Come To Know That The Appellant

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 142(1)Section 144Section 282(1)

circumstances, the AO proceeded with making best judgement assessment u/s. 144 of the Act treating the cash deposit of Rs. 65,19,994/- as unexplained money of the appellant and made additions on account of rental income of Rs. 1,60,202/-, income from other sources

Trikkalangode Vanitha Cooperative Society Ltd, Malappuram vs. ITO, Ward 1, Tirur

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

ITA 958/COCH/2024[2019-20]Status: DisposedITAT Cochin31 Jul 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2019-20 Thrikkalangode Vanitha Co-Op. Society Ltd. .......... Appellant Thrikkalangode, Malapuram 676123 [Pan: Aafat1812K] Vs. The Income Tax Officer, Ward-1., Tirur .......... Respondent Appellant By: Shri Arjun Nedungadi, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 09.06.2025 Date Of Pronouncement: 31.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 30.09.2024 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. No Regular

For Appellant: Shri Arjun Nedungadi, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139Section 139(1)Section 147Section 148Section 68Section 69Section 69ASection 80ASection 80P

made addition of cash deposit of Rs. 1,24,56,550/- made in the account maintained with Manjari Co-operative Urban bank Ltd. as unexplained money of the appellant. Also made addition of unexplained cash credit of Rs. 26,03,873/- and interest income