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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

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Sri Rama Jewellery Mart, Trichy

Appeal stand dismissed

ITA 3334/CHNY/2024[2020-21]Status: DisposedITAT Chennai27 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.3334/Chny/2024 (िनधा'रण वष' / Assessment Year: 2020-21) Dcit Sri Rama Jewellery Mart बनाम/ Vs. Central Circle-2, # 170, Big Bazar Trichy. Trichy-620 008. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabfs-0686-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Ms. Guathami Manivasagam (Jcit) - Ld. Sr. Dr " थ" की ओर से/Respondent By : Shri N. Arjun Raj & Shri S. Girish Kumar (Advocates) - Ld. Ars सुनवाई की तारीख/Date Of Hearing : 08-05-2025 घोषणा की तारीख /Date Of Pronouncement : 27.06.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2020-21 Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals), Chennai-19 [Cit(A)] On 29-10-2024 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) On 29-09-2022. The Grounds Of Appeal Read As Under: - 1. The Order Of The Learned Commissioner Of Income Tax (Appeals) Is Erroneous On Facts Of The Case & In Law. 2 The Ld. Cit (A) Erred In Deleting The Addition Of Rs.51,80,002/- Made Towards Unexplained Money U/S.69A & In Accepting That The Assessee Was Able To Demonstrate The Availability Of Cash, Including Cash Sales That Were Properly Recorded In The Books Of Accounts & Submitted Relevant Supporting Documents, Including The Cash Book, Which Reflected The Cash Balance Of Rs.51,80,002/-Without Appreciating The Fact That The Cash

For Appellant: Ms. Guathami Manivasagam (JCIT) - Ld. Sr. DRFor Respondent: Shri N. Arjun Raj & Shri S. Girish Kumar
Section 133ASection 143(3)Section 69ASection 69C

facts of the case and in law. 2 The Ld. CIT (A) erred in deleting the addition of Rs.51,80,002/- made towards unexplained money u/s.69A and in accepting that the assessee was able to demonstrate the availability of cash, including cash sales that were properly recorded in the books

Ark Cartons Pvt. Ltd., Pune vs. ITO, Ward 8(1) Pune, Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 720/PUN/2025[2017-18]Status: DisposedITAT Pune26 Jun 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.720/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Ark Cartons Private Limited, V The Income Tax Officer, 67/9, D-3 Block, Midc, S Ward-8(1), Pune-44. Chinchwad, Pune – 411019. Maharashtra. Pan: Aanca6083B Appellant/ Assessee Respondent / Revenue Assessee By Shri Rinkesh Gupta – Ca Revenue By Shri Rajesh Haladkar – Addl.Cit(Dr) Date Of Hearing 24/06/2025 Date Of Pronouncement 26/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961, Dated 17.01.2025 Emanating From The Assessment Order Passed U/S.143(3) Of The Income Tax Act, 1961, For A.Y.2017-18 Dated 23.12.2019. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & Circumstances Of The Case, The Ld. Assessing Officer Erred In Adding & Ld. Commissioner Of Income Tax (Appeals)

Section 115BSection 143(3)Section 250Section 40Section 69A

No.720/PUN/2025 [A] erred in confirming the various additionissionccount of cash deposits in deposits in the bank account of Rs. 18,50,000/- as unexplained money u/s 69A of the Income Tax Act, 1961 without properly appreciating the facts of the case. The Appellant prays that the entire addition may please