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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

Rupalkumar Kantilal Shah, Mandvi vs. CIT(A), Delhi

In the result, the appeal of the assessee is dismissed

ITA 56/RJT/2024[AY 2017-18]Status: DisposedITAT Rajkot18 Jul 2025

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 56/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Rupalkumar Kantilal Shah Vs. Cit(A), Delhi Harihant Kt Shah Road, Sheth Wali Delhi – 110001 Street, Na Vapora, Mandvi - 370465 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aoyps3626J (Appellant) (Respondent) Appellant By : Shri Samir Bhuptani, Ld. Ar Respondent By : Shri Dheeraj Kumar Gupta, Ld. Sr. Dr Date Of Hearing : 15/07/2025 Date Of Pronouncement : 18/07/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 06.12.2023, Which In Turn Arises Out Of An Assessment Order Passed By Income Tax Department / Assessing Officer Under Section (U/S.) 144 Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 27.11.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Followed: 1. The Learned Cit(A) Has Erred On Facts In Not Considering The Regularity & Consistency Of Business Even Though The Same Has Been Acknowledged In The Order 2. The Learned Cit(A) Has Erred On Facts In Not Considering The Evidence Furnished By Your Appellant During The Course Of The Proceedings. 3. The Learned Cit(A) Has Erred In Law In Invoking The Provision Of Section 69A To Determine & Tax Income In The Hands Of Your Appellant.

For Appellant: Shri Samir Bhuptani, Ld. ARFor Respondent: Shri Dheeraj Kumar Gupta, Ld. Sr. DR
Section 139(1)Section 142(1)Section 144Section 246A(1)(a)Section 69A

which addition of Rs. 20,64,950/- was made out of which Rs. 18,95,420/- was considered as unexplained money u/s 69A of the act and Rs. 1,69,531/- as commission income of agency business of milk. The appellant is aggrieved with the additions made in while assessing

Lalji Yadav, Lucknow vs. ITO-1(2), Lucknow

In the result, the appeal of the assessee is allowed

ITA 729/LKW/2024[2017-18]Status: DisposedITAT Lucknow18 Jul 2025AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Lalji Yadav, Vs. Ito-1(2), 3/152A, Vivek Khand, Gomti Lucknow (New) Nagar, Lucknow, U.P.-226010 Pan:Aakpy2220J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 06.05.2025 Date Of Pronouncement: 18.07.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 Confirming The Penalty Levied Under Section 272A(1)(D) Levied By The Ito, Ward-9(1)(1), Lucknow Dated 27.01.2022. The Grounds Of Appeal Are As Under:- “1. Because The Assessment Order Dated 10.12.2019 Passed U/S 144 Of The Income Tax Act, 1961, Giving Rise To The Penalty Proceedings U/S 272A(1)(D) Of The Act, Has Been Set Aside By The Hon'Ble Income Tax Appellate Tribunal, Lucknow Bench 'A' Vide Order Dated 13.11.2024 Passed In Ita No. 448/Lkw/2024, Restoring The Matter To The Assessing Officer For Passing The Assessment Order Afresh, The Impugned Order Dated 09.10.2024 Passed By Ld. "Cit(A)" As Well As Penalty Order U/S 272A(1)(D) Do Not Survive & Consequently The Order Passed By The Lower Authorities Deserve To Be Set Aside. 2. Because The Order Appealed Against Is Contrary To Facts, Law & Principles Of Natural Justice. 3. The Appellant Craves Leave To Add, Delete Or Modify Any Of The Grounds Before Or At The Time Of Hearing Of Appeal.”

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR
Section 139(1)Section 142(1)Section 144Section 250Section 272A(1)(d)Section 69A

cash deposits of Rs.1,81,48,000/- and other credit entries appearing in the bank account, of Rs.1,72,19,575/-, was unexplained money under section 69A of the Income Tax Act and he, therefore, added the same back to the income of the assessee. He also initiated penalty proceedings