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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

Nt Manikanden, Madurai vs. ITO, Ncw-2(4), Madurai

In the result, the appeal filed by the assessee is allowed

ITA 189/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Jul 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.189/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Nt Manikanden, Vs. The Income Tax Officer, No. 6-1-95, Moovendar Nagar, Main Non Corporate Ward 2(4), Road, Viswanathapuram, Madurai. Krishnapuram, Madurai 625 014. [Pan:Adlpn0939R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.06.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.01.2025 Passed By The Addl./Jcit(A)-1, Surat For The Assessment Year 2017-18. 2. The Assessee Raised 4 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under Section 69 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 69Section 69A

lease agreements. The Assessing Officer did not accept the said submissions and proceeded to add an amount of ₹.16,50,000/- on account of unexplained money under section 69A of the Act. Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before ... order of the ld. CIT(A) is not justified in confirming the order of the Assessing Officer in making addition on account of unexplained money under section 69A of the Act. Thus, the grounds raised by the assessee are allowed. 8. In the result, the appeal filed by the assessee

Panimayam Jesuraja, Pudukottai vs. ITO, Circle-2(1), Trichy

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

ITA 1318/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.1317 & 1318/Chny/2025 िनधा"रण वष"/Assessment Years: 2013-14 & 2015-16 Panimayam Jesuraja, Vs. The Income Tax Officer, 55, Kallusanthu Aranthangi, Circle 2(1), Radhanallur B.O., Trichy/Tanjore. Pudukottai 614 616. [Pan:Auppj9253R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Hitesh, Advocate For Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit & Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 17.03.2025 & 19.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2013-14 & 2015-16 Respectively.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT &
Section 133(6)Section 139Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

ICICI bank account from various entities. Since the assessee could not explain with documentary evidences, the Assessing Officer treated the same as unexplained money under section 69A of the Act and added to the total income of the assessee. Further, on verification of the ITR filed by the assessee

Panimayam Jesuraja, Pudukottai vs. ITO, Circle-2(1), Trichy

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

ITA 1317/CHNY/2025[2013-14]Status: DisposedITAT Chennai17 Jul 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.1317 & 1318/Chny/2025 िनधा"रण वष"/Assessment Years: 2013-14 & 2015-16 Panimayam Jesuraja, Vs. The Income Tax Officer, 55, Kallusanthu Aranthangi, Circle 2(1), Radhanallur B.O., Trichy/Tanjore. Pudukottai 614 616. [Pan:Auppj9253R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Hitesh, Advocate For Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit & Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 17.03.2025 & 19.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2013-14 & 2015-16 Respectively.

For Appellant: Shri Hitesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT &
Section 133(6)Section 139Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

ICICI bank account from various entities. Since the assessee could not explain with documentary evidences, the Assessing Officer treated the same as unexplained money under section 69A of the Act and added to the total income of the assessee. Further, on verification of the ITR filed by the assessee

Ramesh Mangilal, Kolathur vs. Income-Tax Officer, Non Corp Ward 10(3), Nungambakkam

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

ITA 1050/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Jul 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1050/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Ramesh Mangilal, Vs. The Income Tax Officer, 8, Ayyappa Nagar Extension, Non Corporate Ward 10(3), Vinayagapuram, Kolathur, Chennai. Chennai 600 099. [Pan:Agvpr4889B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Arihanth Jain, C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 01.07.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 3 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A)

For Appellant: Shri Arihanth Jain, C.AFor Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 68

r.w.s. 144 r.w.s. 144B of the Act dated 30.03.2022 by treating the cash deposit to an extent of ₹.1,40,28,200/- as unexplained money under section 68 of the Act and added to the total income of the assessee. 4. The assessee carried the matter in appeal before

Incometax Officer, Thriuvallur vs. Gt60 Arungulam Primary Agri Cooperative Credit Society, Tiruttani

In the result, the appeal filed by the Revenue is dismissed

ITA 2781/CHNY/2024[2018-19]Status: DisposedITAT Chennai17 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2781/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 The Income Tax Officer, Vs. Gt60 Arungulam Primary Agri Ward 1, Cooperative Credit Society, Tiruvallur. No. 1, Periya Theru, Thumbikulam Village, Thalavedu Post & Taluk, Tiruvallur 631 212. [Pan: Aabag2568F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. R. Anita, Addl. Cit ""थ" की ओर से/Respondent By : Shri Malar Mannan, Advocate सुनवाई की तारीख/ Date Of Hearing : 02.06.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 26.07.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 24 Days. The Ito, Ward 1, Tiruvallur Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said

For Appellant: Ms. R. Anita, Addl. CITFor Respondent: Shri Malar Mannan, Advocate
Section 142(1)Section 148Section 69ASection 69C

cash deposits and withdrawals with the information on record and completed the assessment by making additions towards cash deposits of ₹.10,24,090/- as unexplained money under section 69A of the Act and withdrawals at ₹.1,04,00,501/- as unexplained expenditure under section 69C of the Act. 5. Aggrieved ... account and further, all these transactions have been duly recorded in the books of account. Hence, the above said deposits cannot be considered as "unexplained money" in the hands of the assessee." Similar view has been expressed by the Hon'ble ITAT BENGALURU "C" BENCH, BENGALURU in the case

Abhay Hargovindbhai Patel, Jamnagar vs. The Income Tax Officer, Jamnagar

In the result, the appeal filed by the assessee is partly allowed, in above terms

ITA 17/RJT/2024[2017-18]Status: DisposedITAT Rajkot16 Jul 2025AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपीलसं./Ita No. 17/Rjt/2024 निर्धारणवर्ष / Assessment Year: (2017-18) (Hybrid Hearing) Abhay Hargovindbhai Patel Vs. The Income Tax Officer, Ward 305, Dwarkeshdham,B/H. Samudra 1(3), Jamnagar Sales, Rajnagar, Aerodram Road, 1St Floor, Taranjali Building, Pn Jamnagar 361006 Marg, Aubpp7196D Jamnagar 361008 (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. (Dr) Date Of Hearing : 27/04/2025 Date Of Pronouncement : 16/07/2025 आदेश / Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By Commissioner Of Income Tax (Appeals), Vide Order Dated 08/11/2023, Which In Turn Arises Out Of An Order Passed By The Assessing Officer, Dated 26/11/2019, U/S 144 Of The Income Tax Act, 1961. Page 1

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri K. L. Solanki, Ld. Sr. (DR)
Section 120(5)Section 133(6)Section 139Section 142(1)Section 144Section 69A

erred on facts and in law in making addition of Rs. 40,16,900/- by considering the cash deposited in bank account as alleged unexplained money u/s. 69A and the learned CIT(A) has erred in confirming the same. 3. Succinctly, the factual panorama of the case is that assessee ... period as well as during the year under consideration in his bank account No. 18940100010833 maintained with Bank of Baroda, Khodiyar Colony, Jamnagar as unexplained money within the meaning of section 69A read with section 115BBE of the Income Tax Act, 1961 for the year under consideration. Accordingly, addition