“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

Prathik Ravikumar, Bangalore vs. Income Tax Officer, Ward-2(2)(2), Bangalore

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

ITA 1015/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Jul 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2018-19

For Respondent: Shri Avinash Mallya

Section 142(1)Section 148

with the explanations had confirmed the cash deposits made into his bank account in JSCBL Bank Page 2 of 4 and Axis Bank as unexplained money. As against the said order, the assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) had issued several notices on 13/12/2024, 03/01/2025 ... bank accounts were all bank transfers effected by his father and his mother and therefore the said deposits could not be treated as unexplained money. The Ld.AR further submitted that the necessary proofs and confirmation of the credits into the bank account were available with him and the said documents

Ajay Mahesh Shivdasani, Thane vs. Circle 1, Kalyan

ITA 2558/MUM/2025[2017-18]Status: DisposedITAT Mumbai25 Jul 2025AY 2017-18

Bench: Smt. Beena Pilla (Jm) & Shri Omkareshwar Chidara (Am) Ajay Mahesh Shivdasani Acit, Circle-2 Flat 201, Konark Residency Mohan Plaza, Near Near Shahad Station Vs. Poddar School, Vaile Ulhasnagar-1, Thane Nagar, Kahadkpada Maharashtra-421 001. Kalyan, Dombivali Pan : Bcbps3471B Appellant Respondent

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Sanket Joshi(Virtually)

Section 115BSection 144Section 145(3)Section 250Section 68Section 69A

addition of Rs. 1,02,17,000 made by the A.O. by taxing the entire cash deposits in bank account during demonetization period as unexplained money u/s 69A is apparently unjustified on facts and in law and hence, the said addition may please be deleted. 2. From the above

Satish Narayan Tarale, Belgavi vs. Intl.Taxation Ward, Panaji

ITA 55/PAN/2025[2019-20]Status: DisposedITAT Panaji24 Jul 2025AY 2019-20

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 055/Pan/2025 Assessment Year : 2019-20 Satish Narayan Tarale 35, Laxmi Narayan Niwas, 2Nd Stage, Hanuman Nagar, Belgaum-590001. Pan : Afkpt0032Q . . . . . . . Appellant V/S The Income Tax Officer, International Taxation Ward, Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr Pramod Vaidya [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 11/06/2025 घोषणा की तारीख / Date Of Pronouncement : 24/07/2025 Order Per G. D. Padmahshali; The Captioned Appeal Is Filed By The Assessee Challenges Din & Order No Itba/Ast/F/144/2024- 25/1072202908(1) Dt. 15/01/2025 Passed By The Income Tax Officer, International Taxation Ward, Panaji Goa [‘Ld. Ao’] U/S 144 R.W.S. 144C(13) Of The Income-Tax Act, 1961 [‘The Act’] Anent To Assessment Year 2019-20 [‘Ay’].

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]

Section 115BSection 139(1)Section 144Section 144C(1)Section 148Section 253(6)Section 3Section 4Section 6(6)Section 69A

144C(1) of the Act proposed to make addition of entire sums found credited into such bank accounts for ₹50,35,902/- as unexplained money u/s 69A of the Act. The assessee vide application dt. 22/04/2024 4. challaged the said proposition & the draft order before the Dispute Resolution Panel ... occasions. Pursuant to such directions the Ld. AO vide order 5. dt. 15/01/2025 made a solitary addition ₹1,50,000/- u/s 69A as unexplained money and brought same to tax u/s 115BBE of the Act vide final assessment ITAT-Panaji Page 3 of 15 Satish Narayan Tarale

Deepak Auto Sales Kunda Pratapgarh, Pratapgarh vs. Income Tax Officer Pratapgarh, Pratapgarh

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

ITA 69/ALLD/2025[2019-20]Status: DisposedITAT Allahabad24 Jul 2025AY 2019-20

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 142(1)Section 144Section 147Section 148Section 69A

determining total income of the assessee at Rs.2,70,75,760/- by making addition of Rs.2,70,75,740/- on account of unexplained money u/s 69A of the Act and Rs.19.25 on account of TDS. Being aggrieved, the assessee carried the matter in appeal before the learned ... account for the said year. That the assessing officer misunderstood the facts and made the addition on account of entire deposits as unexplained money u/s 69 of the Act when the said bank account already disclosed in the financial statement and the sales also disclosed in the profit and loss

Rameshwari Agro Services Private Limited, Aurangabad vs. Income Tax Department, NFAC, Delhi

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 188/PAT/2025[2018-19]Status: HeardITAT Patna24 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.187&188/Pat/2025 Assessment Year: 2017-18 & 2018-19 Rameshwari Agro Services Pvt. Ltd.…..…………………....Appellant C/O Lakshman Prasad & Kamlesh Kr. Yadav (Directors), Jai Gurudev Automobile, Gaya Road, Daudnagar, Aurangabad, Bihar-824113. [Pan: Aahcr9701K] Vs. Nfac, Delhi…………………….……….…............................…..…..... Respondent Appearances By: Shri Abhi Sarkar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 24, 2025 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Have Been Filed By The Assessee Against Separate Orders Dated 29.07.24 & 31.07.24 Passed By The Nfac ["Cit(A)"]. Since The Issues Involved In Ita Nos.187 & 188/Patna/2025 For The Assessment Years 2017-18 & 2018-19 Are Identical Except For Figures & Assessment Years, Both Appeals Are Heard Together & Are Being Disposed Of By This Common Order. For The Sake Of Convenience, The Facts Are First Taken From Ita No.187/Patna/2025. 2. Ita No. 187/Patna/ 2025 - A.Y. 2017-18 - Brief Facts Of The Case Are That The Assessee Did Not File Its Return Of Income For The Assessment

Section 144Section 147Section 148Section 69A

explanation, the Assessing Officer completed the reassessment under Section 147 read with Section 144, by treating the entire deposit of Rs.5,17,1450 as unexplained money under Section 69A of the Act and added the same to the total income of the assessee 3. Aggrieved, the assessee filed an appeal

Rameshwari Agro Services Private Limited, Aurangabad vs. Income Tax Department, NFAC, Delhi

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 187/PAT/2025[2017-18]Status: HeardITAT Patna24 Jul 2025AY 2017-18

Section 144Section 147Section 148Section 69A

Income Tax Officer, Sikar vs. Bhaskar Chauhan, Jaipur

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a

Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

Income Tax Act, 1961 which are not applicant in the asssesse's case even distantly. The provisions of section 69A quoted below: - Unexplained money, etc. 69A. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such

Rajendra Singh, Shahjahanpur vs. Ld. AO, Assessment Unit, Jurisdictional AO- ITO-1(4) Shahjahanpur-1, Shahjahanpur

In the result, the appeal is partly allowed for statistical purposes

ITA 645/LKW/2024[2019-20]Status: HeardITAT Lucknow24 Jul 2025AY 2019-20

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 144Section 147Section 148Section 151ASection 69A

erred in law and on facts in confirming the addition of Rs.63,68,160/- made by Assessing Officer treating it as unexplained money u/s 69A of the Act. 4. The CIT(A) has erred in law and on facts in passing appellate order which is contrary to the facts ... determined the total income of the assessee at Rs.63,68,160/-, making addition of Rs.63,68,162/- on account of unexplained money u/s 69A of the Act. Being aggrieved, the assessee carried the matter in appeal before the learned CIT(A), who has dismissed the appeal of the assessee vide

Incometax Officer Ward-3(3)(1), Ahmedabad vs. Haresh Dayashankar Shrivastav, Ahmedabad

In the result the appeal filed by the Revenue is allowed for statistical purpose

ITA 684/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarassessment Year : 2017-18 Income-Tax Officer, Haresh Dayashankar Shrivastav, Vs Ward 3(3)(1), 35, Swetanjali Society, Nr. Ahmedabad Hasubhai Park, Satellite, Ahmedabad-380015 Pan : Bbpps 5719 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Arsh Shaikh, Ar Revenue By : Shri Abhijit, Sr Dr सुनवाई क" तार"ख/Date Of Hearing : 25.06.2025 घोषणा क" तार"ख /Date Of Pronouncement : 24.07.2025 आदेश / O R D E R Per T.R. Senthil Kumar:

For Appellant: Shri Arsh Shaikh, ARFor Respondent: Shri Abhijit, Sr DR

Section 142(1)Section 144

required details. Thereafter, the Ld AO passed the assessment order, treating the cash deposit made during demonetization period of Rs.1,58,43,170/- as unexplained money u/s 69A of the Act and charged to tax u/s 115BBE of the Act. 5.1 The Ld AO also made the other credit entries

Shree Halsidhnath Nagari Sahakari Patsanstha Maryadit, Maharashtra vs. ITO Ward 2(1) Kolhapur, ITO Ward Two One Kolhapur

In the result both the appeals of the assessee are allowed for statistical purposes as per terms indicated above

ITA 872/PUN/2025[2014-15]Status: DisposedITAT Pune24 Jul 2025AY 2014-15

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.870&872/Pun/2025 धििाारण वर्ा / Assessment Year: 2014-15 Shree Halsidhnath Nagari Ito Ward 2(1), Kolhapur Sahakari Patsanstha Vs Maryadit Ari Patsanstha Maryadit K475 E Ward, Shahu Road, Shahupuri, Kolhapur- 416003 Maharashtra Pan No. Aadas0448N Appellant/Assessee Respondent/Revenue

Section 147Section 250Section 250(6)Section 68Section 69A

r.w.s.144B of the Act framed for A.Y. 2013-14 and 2014-15 in which Ld. Assessing Officer (AO) has made the addition for unexplained money u/s 69A of the Act at Rs. 7,60,25,549/- for A.Y. 2013- 14 and addition

Shree Halsidhnath Nagari Sahakari Patsanstha Maryadit, Maharashtra vs. ITO Ward 2(1) Kolhapur, ITO Ward Two One Kolhapur

In the result both the appeals of the assessee are allowed for statistical purposes as per terms indicated above

ITA 870/PUN/2025[2013-14]Status: DisposedITAT Pune24 Jul 2025AY 2013-14

Section 147Section 250Section 250(6)Section 68Section 69A

Salt Lake Service Station, Kolkata vs. DCIT, 49(1), Kolkata

Appeal is partly allowed

ITA 431/KOL/2025[2017-18]Status: DisposedITAT Kolkata24 Jul 2025AY 2017-18

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115BSection 250Section 271ASection 36Section 36(1)(v)Section 36(1)(va)Section 37(1)Section 40Section 69A

Appeal Centre was not justified in treating the cash deposits to bank during the demonetization period amounting to Rs. 6,06,52,500/- as unexplained money u/s 69A of the Income Tax Act, 1961 when such deposits were made into the regular bank account of the Appellant and were part ... correct and there was no doubt about the source thereof. Only for the 2 months of demonetization period, all cash deposit was considered as unexplained money for which recourse to addition under section 69A of the Act was taken. This has been done when all the cash deposit to bank

ITO, Siliguri vs. Shubhasish Dey, Siliguri

Appeal of the Revenue is allowed for statistical purposes

ITA 1163/KOL/2023[2017-18]Status: DisposedITAT Kolkata24 Jul 2025AY 2017-18

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 142(1)Section 144Section 250Section 69A

comply with notices issued by the Ld. AO and hence the cash deposit during demonetisation period was added to his income as unexplained money u/s 69A of the Act. 2 Subhasish Dey 1.1 The assessee carried this matter in appeal where he succeeded on the basis of the following findings ... that was duly reflected in the audited financials. The AD without verifying these facts treated entire cash credit of Rs.1,09,82,691/- as unexplained money. The AO is directed to delete the addition of Rs. 1,09,82.691/- made as unexplained money

E 2672 Vallampadugai Primary Agricultural Co-Op Credit Society Limited, Cuddalore vs. ITO Ward 2, Cuddalore

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

ITA 717/CHNY/2025[2019-20]Status: DisposedITAT Chennai24 Jul 2025AY 2019-20

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:717/Chny/2025 िनधा"रण वष" / Assessment Year: 2019-20 E-2672 Vallampadugai Primary Ito, Agricultural Co-Op Credit Society Ltd, Vs. Ward -2, E-2672, Vallampadugai S.O, Cuddalore. Vallampadugai, Cuddalore – 608 401. [Pan:Aabav-0643-E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. G. Reddi Prakash, C.A. ""थ" की ओर से/Respondent By : Ms. Pryati Sharma, J.C.I.T.

For Appellant: Shri. G. Reddi Prakash, C.AFor Respondent: Ms. Pryati Sharma, J.C.I.T

Section 144Section 147Section 69A

dated 22.02.2024 by adding the amount of Rs.43,50,623/- for the year under consideration u/s.69A r.w.s.115BBE of the Act as unexplained money. :-3-: ITA. No:717/Chny/2025 4. Aggrieved by the order of the Assessing Officer, the assessee filed an appeal before the ld. CIT (A), NFAC, Delhi. 5. Before

Ghousemunavardeen Zainab Banu, Andalpuram, Madurai vs. Income Tax Officer, Non-Corporate Ward 1(7), Madurai, Income Tax Office, Cr Building

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

ITA 1603/CHNY/2025[2014-2015]Status: DisposedITAT Chennai24 Jul 2025AY 2014-2015

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1603/Chny/2025 िनधा"रण वष" / Assessment Year: 2014-15 Ghousemunavardeen Zainab Banu, Ito, B-10, Varapradha, Agrini Vs. Non-Corp Ward -1(7), Andalpuram, Madurai. Madurai– 625 003. [Pan:Aaqpz-2950-E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. T. Vasudevan, Advocate. ""थ" की ओर से/Respondent By : Mr. Arv Sreenivasan, Cit.

For Appellant: Shri. T. Vasudevan, AdvocateFor Respondent: Mr. ARV Sreenivasan, CIT

Section 144Section 147Section 50CSection 69

section 50C of the act of Rs.1,04,16,995/-) to the total income for the year under consideration u/s.69 of the Act as unexplained money. 4. Aggrieved by the order of the Assessing Officer, the assessee filed an appeal before the ld. CIT (A), NFAC, Delhi

Income Tax Officer, Ward-1 & Tps, Bagalkot, Aayakar Bhavan vs. Shri Shivashakti Souharda Pattina Sahakari Sangha Niyamit

In the result, appeal is partly allowed

ITA 517/BANG/2025[2017-18]Status: DisposedITAT Bangalore24 Jul 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Siddesh N Gaddi, CAFor Respondent: Shri. Murali Mohan M, CIT(DR)(ITAT), Bangalore

Section 143(2)Section 156Section 234ASection 270ASection 271ASection 68Section 80PSection 80P(2)(a)

members and therefore the assessee did not got any benefit on the same. The AO treated the entire amount of Rs.99,20,508/- as unexplained money and taxed under section 115BBE of the Act. 5. Aggrieved from the above Order, assessee filed appeal before the CIT(A). Assessee submitted detailed

Shri Shivashakti Souharda Pattina Sahakari Sangha Niyamit, Melligeri Towers, Bagalkot vs. Income Tax Officer Ward 1 Bagalkot, Aayakar Bhavan

In the result, appeal is partly allowed

ITA 452/BANG/2025[2017-18]Status: DisposedITAT Bangalore24 Jul 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Siddesh N Gaddi, CAFor Respondent: Shri. Murali Mohan M, CIT(DR)(ITAT), Bangalore

Section 143(2)Section 156Section 234ASection 270ASection 271ASection 68Section 80PSection 80P(2)(a)

Alka Rajesh Vanigota, Mumbai vs. Commissioner of Income Tax (A)-52, Mumbai

In the result, appeal of the assessee is allowed

ITA 349/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10(38)Section 143(1)Section 147Section 69Section 69A

form of pre-arranged bogus LTCG. Thus Rs.8548487/- is hereby added with the returned income u/s 69A of the IT Act as unexplained money in the form of pre-arranged bogus LTCG. 7 Alka Rajesh Vanigota 5. Although no specific adverse comments have been made by the Assessing Officer with

Anshul Gupta, Gurugram vs. Income Tax Officer, Mumbai

In the result, the grounds of appeal raised by the assessee are

ITA 2320/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17

Bench: Shri Pawan Singh & Ms. Padmavathy S

Section 144Section 254(1)Section 69A

have gone through the orders of lower authorities carefully. We find that AO completed assessment under section 144/ 147 and made additions of unexplained money and credits. The additions were made on the allegation of TEP. On appeal before ld CIT(A), the assessee filed application for filing additional evidences

Anshul Gupta, Gurugram vs. Income Tax Officer, Mumbai

In the result, the grounds of appeal raised by the assessee are

ITA 2319/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: Shri Pawan Singh & Ms. Padmavathy S

Section 144Section 254(1)Section 69A