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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

Jethanand H Varandani (HUF), Kolkata vs. I.T.O., Ward - 29(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 2521/KOL/2024[2018-2019]Status: DisposedITAT Kolkata23 Jul 2025AY 2018-2019

Bench: Shri George Mathanआयकर अपील सं/Ita No.2521/Kol/2024 (नििाारण वर्ा / Assessment Year :2018-2019) Jethanand H Varandani (Huf) Vs Ito, Ward-29 (1), Kolkata/ Flat No.101, Block-A2, Assessment Unit, Income Tax Brindavan Gardens 98, Department, Mof, Goi Christopher Road, Kolkata-700046 Pan No. : Aaghj 8544 J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Somnath Ghosh, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 23.10.2024 For The Assessment Year 2018-2019. 2. Shri Somnath Ghosh, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. It Was Submitted By The Ld. Ar That The Assessee Had During The Assessment Year 2017-2018 & The Impugned Assessment Year 2018- 2019 Sold Saree To M/S Faithful Cloth Merchants Pvt. Ltd.. The Total Sales Was To An Extent Of Rs.30,13,950/-, However, It Was The Submission That The Ao Has Taken Figure At Rs.30,11,125/-. It Was The Submission That The Assessee Had Sold During The Assessment Year 2017-2018 Sarees To An Extent Of Rs.15,08,700/- & During The Impugned Assessment Year Sarees Were Sold At Rs.15,02,250/-. The Ld.Ar Drew My Attention To Page 19 Of The 2 Paper Book Which Is Ledger Account Of The Assessee In The Books Of M/S Faithful Cloth Merchants Pvt. Ltd., Which Reads As Follows :-

For Respondent: Shri Shankar Naskar, Sr. DR
Section 133(6)Section 44ASection 69A

bridge slips provided, the Assessing Officer treated the sale to M/s Faithful Cloth Merchants Pvt. Ltd. as bogus transaction and treated the same as unexplained money received by the assessee. It was the submission that the transactions having been proved, insofar as M/s Faithful Cloth Merchants Pvt. Ltd. having confirmed ... submissions. At the outset, a perusal of the assessment order shows that the Assessing Officer has treated the amount at Rs.30,11,125/- as unexplained money u/s.69A of the Act. The turnover of the assessee in the impugned assessment year is at Rs.15,02,250/-. The turnover of the assessee

Ganesh Mahato, Durgapur, South Parganas vs. Assistant Commission of Income Tax Circle 26(1), Kolkata

In the result, the appeal is allowed for statistical purposes, with cost of Rs

ITA 182/KOL/2024[2017-2018]Status: DisposedITAT Kolkata23 Jul 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.182/Kol/2024 Assessment Year: 2017-18 Ganesh Mahato…...……………………..…………………....Appellant Vill. Durgapur, Po- Jaynagar, Majilpur, South 24 Parganas-743337. [Pan: Bgppm6996K] Vs. Acit, Circle-26(1), Kolkata ……………..………………….…..... Respondent Appearances By: Shri Ankit Jalan, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 23, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 01.12.2023 Passed By The Nfac [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring Total Income Of Rs.3,76,470/-. The Case Was Selected For Limited Scrutiny. Notices Under Sections 143(2) & 142(1) Were Issued But She Assessee Remained Non-Compliant. The Assessing Officer Observed That Total Deposits In The Assessee'S Bank Accounts With Bank During The Period April 2016 To March 2017 Amounted To Rs.2,00,80,900, Whereas The Assessee Had Shown Only Rs.90,20,200 As Sales. The Excess Deposit Of Rs.1,10,60,700 Was Treated As Unexplained Money Under Section 69A & Added To The Income Of The Assessee.

Section 144Section 250Section 69A

whereas the assessee had shown only Rs.90,20,200 as sales. The excess deposit of Rs.1,10,60,700 was treated as unexplained money under Section 69A and added to the income of the assessee. I.T.A. No.182/Kol/2024 Ganesh Mahato Assessment was completed under Section 144 determining total income at Rs.1