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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

Bhupendra Flour Mills Pvt Ltd, Bathinda vs. ITO, Ward 1(1), Bathinda

The appeal stands partly allowed in terms of out above order

ITA 54/ASR/2025[2017-18]Status: DisposedITAT Amritsar20 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayandasgupta, Jm आयकरअपीलसं. / Ita No.54/Asr/2025 (िनधा"रणवष" / Assessment Year: 2017-18) M/S Bhupendra Flour Mills Pvt Ltd. Ito Ward - 1(1) बनाम/ Railway Road Central Revenue Building Bhatinda, Punjab – 151001 Civil Lines, Bhatinda Vs. Punjab - 151001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccb-6192-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

For Appellant: Sh. Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Sh. Farhat Khan (CIT) – Ld. DR (Virtual)
Section 10(37)Section 14Section 143(3)Section 145B(1)Section 194LSection 2Section 2(24)Section 36Section 4Section 45(5)

Bank at Delhi earned from the sources not disclosed to the department. Hence, an amount of Rs.2,33,00,000/- is held as unexplained money u/s 69A of the assessee from undisclosed sources and tax will be charged on assessed income as per provision of section 115BBE of the Income ... Finally, the amount of Rs.233 Lacs was added to the income of the assessee as unexplained money u/s 69A. The Ld. CIT(A) confirmed the stand of Ld. AO against which the assessee is in further appeal before us. 5. It emerges that the assessee is a corporate entity

Sandeep Vishnu Redekar, Belagavi vs. Income Tax Officer, Ward - 1, Gokak

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

ITA 36/PAN/2026[2017-18]Status: DisposedITAT Panaji20 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. No.36/Pan/2026 (A.Y. 2017-18) Sandeep Vishnu Redekar, Vs I T O Ward(1), H.No.103,Daddi,Tal-Hukkeri, Dr Ghogeri Building, . Belgavi-591254, Belgaum Road, Karnataka. Gokak-591307, Karnataka. Pan: Amwpr8609J (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Swapnil Patil.Ar Revenue By Shri.Sanket Deshmukh.Sr.Dr सुनवाई की तारीख/Date Of Hearing 18.02.2026 घोषणा की तारीख/Date Of Pronouncement 20.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Addl/Jcit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Ex-Parte Order Of The Cit(A) Sustaining The Addition Of Commission & Unexplained Money U/Sec69A Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is Engaged In The Business Of Dealing With The Sale Of Prepaid Charges Of Mobile To Customers. The Assesee Has Filed The Return Of Income For A.Y.2017-2018 On 14.09.2017 Disclosing A Total Income Of Rs.2,68,990/- & The Case

assessee has raised the grounds of appeal challenging the ex-parte order of the CIT(A) sustaining the addition of commission and unexplained money u/sec69A of the Act made by the Assessing Officer. 2. The brief facts of the case are that, the assessee is engaged in the business

Kiran Bala Gupta, Hyderabad vs. ITO, Ward-10(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 341/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.341/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2012-13) Smt. Kiran Bala Gupta, Vs. Income Tax Officer, Hyderabad. Ward-10(1), Pan: Ahvpg6893K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Av Raghuram, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 20/12/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/08/2022 For The Assessment Year (Ay) 2012-13. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 10(38)Section 143(2)Section 143(3)Section 271(1)(c)

Gupta vs. ITO amounts claimed by the assessee to have been received as unsecured loans from 11 parties by treating the same as her unexplained money under section 69A of the Act: Rs.61,00,000/-. Accordingly, the AO vide his order under section 143(3) of the Act, dated 26/03/2015 ... Rs.61 lakhs, which the assessee had claimed to have received from 11 persons, as having been held by the AO as the assessee’s unexplained money under section 69A of the Act, the Ld. AR submitted that though the assessee had furnished the details in the course of the assessment

Sarda Brijgopal, Hyderabad vs. ITO, Ward-5(1), Hyderabad

ITA 1891/HYD/2025[2017-18]Status: DisposedITAT Hyderabad20 Feb 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1891/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Sarda Brijgopal, Vs. Income Tax Officer, Hyderabad. Ward-5(1), Pan: Aamhs2717L Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ms. Aluru V Sai Sudha, Ca राज" व "ारा/Revenue By: Shri K. Vamsi Krishna, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-4, Chennai, Dated 30/09/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 18/12/2019 For The Assessment Year (Ay) 2017-18. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Ms. Aluru V Sai Sudha, CAFor Respondent: Shri K. Vamsi Krishna, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 234BSection 69A

rejecting the explanation of the assessee held the entire amount of cash deposit of Rs.10,43,500/- as having been sourced out of his unexplained money under section 69A of the Act. Accordingly, the AO vide his order under section 143(3) of the Act, dated 18/12/2019 determined the income ... amount of cash deposits of Rs. 10.43 lakhs (approx.) made by the assessee during the demonetization period as having been sourced out of his unexplained money under section 69A of the Act. Elaborating on her contention, the Ld. AR submitted that the assessee as on 31/03/2016 had available with