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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

Srilakshmi Devireddy, Vijayawada vs. Income Tax Officer, Ward-3(5), Vijayawada

ITA 428/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam19 Feb 2026AY 2017-18

Bench: Shri Ravish Sood, Hon'Bleआयकर अपीलसं./I.T.A.No.428/Viz/2025 (निर्धारण वर्ष/ Assessment Year:2017-18) Srilakshmi Devireddy Vs. Income Tax Officer, Ward-3(5) D.No. 9-58, Loyabata Road Nunna, Vijayawada – 521212 Andhra Pradesh [Pan: Bjupd8440D] Vijayawada करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By Shri C. Subrahmanyam, Ca Shri D. Hema Bhupal, Sr.Dr सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing 16.02.2026 घोषणा की तारीख/Date Of Pronouncement 19.02.2026 Per Ravish Sood, Jm: आदेश /Order 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 12.11.2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O”) Under Section 143(3) Of The Income-Tax Act, 1961 (For Short, "The Act"), Dated 03.12.2019 For The Assessment Year 2017-18. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

Section 139(4)Section 142(1)Section 143(3)Section 250Section 250(6)Section 69A

held the entire amount of cash deposits of Rs.11,00,000/- made in her two bank accounts as having been sourced from her unexplained money under section 69A of the Act and framed the assessment vide his order passed under section 143(3) of the Act, dated 03.12.2019. Page ... made in her bank account, therefore, the AO had held the same as having been sourced out of her unexplained money under section 69A of the Act. Also, I find that the assessee, even before the authorities below, had failed to discharge the onus that was cast upon

Joint Commissioner of Income Tax(OSD), Subhash Road vs. Windlass Constructions, Rajpur Road

In the result, appeal of the Revenue is dismissed

ITA 33/DDN/2025[2017-18]Status: DisposedITAT Dehradun18 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] Jcit (Osd) Vs Windlass Constructions Aaykar Bhawan, 53-R, Rajpur Road 13 A, Subhhash Road, Uttarakhand-248001 Uttarakhand Pan-Aabfw4972E Appellant Respondent Revenue By Shri A.S.Rana, Sr.Dr Assessee By Shri Varendra Kalra, Ca Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 19.12.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Dehradun/10687/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 20.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Partnership Firm & E-Filed Its Return Of Income On 31.10.2017, Declaring Loss Of Inr 4,61,33,210/-. The Case Was Selected For Scrutiny Under Cass For Various Reasons Where One Of The Reasons Was That Large Cash Was Deposited During Demonetization Period. The Assessee Has Deposited Cash Of Inr 2,40,32,000/- During The Demonetization Period For Which It Was Explained That The Immediate Source Was Out Of The Withdrawals Made Prior To The Deposits. Ao Observed That Cash Was Withdrawn For Business Activities & Were Spent & Therefore, The Source Of The Cash Remained Unexplained & Made The Addition U/S 69A As Unexplained Money & Invoked The Provision Of Section 115Bb Of The Act.

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

withdrawn for business activities and were spent and therefore, the source of the cash remained unexplained and made the addition u/s 69A as unexplained money and invoked the provision of section 115BB of the Act. 3. Against the said order, the assessee preferred appeal before Ld.CIT(A) who vide impugned ... case and in law, whether the CIT (A) is justified in deleting the addition of Rs. 2,26,50,000/- made on account of unexplained money accrued to the assessee. 2. On facts and circumstances of the case and in law, whether the CIT (A) while allowing relief

Pardeep Kumar Walia, Dehradun vs. DCIT Central Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 168/DDN/2025[2023-24]Status: DisposedITAT Dehradun18 Feb 2026AY 2023-24

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Pradeep Kumar Walia Vs Dcit C/O-Matta Garg & Co. Central Circle 15, Astley Hall Dehradun Dehradun, Uttarakhand Uttarakhand-248001 Pan-Aabpw2423F Appellant Respondent Assessee By Shri S.K.Matta, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 31.07.2025 By Ld. Commissioner Of Income Tax (A)-3, Noida [“Ld.Cit(A)”] In Appeal No. Cit(Appeals) Noida-3/10009/2022-23 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 07.02.2025 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2023-24. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed His Return Of Income U/S 139(4) Of The Act On 04.11.2023, Declaring Total Income Of Inr 86,20,630/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass For The Reason That The Assessee Has Claimed Deduction U/S 54F Of The Act & Corresponding Capital Gain Was Not Declared In The Return Of Income Filed By The Assessee.

Section 115BSection 139(4)Section 143(3)Section 250Section 54FSection 69A

Lumba which was offered as income by the assessee. The AO invoked the provision of section 69A and held that such cash loan as unexplained money and further, made the addition of Rs. 25.00 lacs and invoked the provision of section 115BBE of the Act and applied higher rate ... therefore the provisions of section u/s 69A of the Act could not be applied. The provisions of section 69A are read as under:- Unexplained money, etc. 69A. “Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article

Income Tax Officer, Dehradun vs. Rakesh Mohan Verma, Dehradun

In the result, appeal of the Revenue is dismissed

ITA 122/DDN/2024[2017-18]Status: DisposedITAT Dehradun18 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] Ito Vs Rakesh Mohan Verma Ward-1(1)(3) 144, Neshvilla Road, Aaykar Bhawan, Dehradun, Uttarakhand- 13 A, Subhhash Road, 248001 Uttarakhand Pan-Abbpvcv4728J Appellant Respondent Revenue By Shri A.S.Rana, Sr.Dr Assessee By Shri Amit Arora, Ca & Shri Vishal Mishra, Ca Date Of Hearing 09.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 15.05.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A) Dehradun/10729/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 27.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income, Declaring Total Income 10,94,900/-. The Case Of The Assessee Was Selected For Scrutiny Through Cass With The Issue “Large Cash Deposits Compared To Returned Income”. Notice U/S 143(2) Was Issued On 08.08.2018, Followed By Notices U/S 142(1) Issued From Time To Time. In Response, The Assessee Filed Replies & Produced All The Information & Supporting Documentary Evidences For Examination. The Ao Vide Order Dated 27.12.2019 Passed U/S 143(3) Of The Act Assessed The Income Of The Assessee At Inr 1,53,25,642/- Wherein Addition Of Inr 69,81,000/- Is Made As Unexplained Money U/S 69A Of The Act Towards The Bank Deposits & Further Inr 9,60,568/- Added As Unexplained Income Being Difference Between Deposits & Income Declared. Further An Addition Of Inr 62,89,172/- Is Made As One Fourth Payments Against Loan Repayment Of Rs.251,56,689/- Repaid From Undisclosed Sources U/S 69A Of The Act.

Section 142(1)Section 143Section 143(2)Section 143(3)Section 250Section 69A

assessed the income of the assessee at INR 1,53,25,642/- wherein addition of INR 69,81,000/- is made as unexplained money u/s 69A of the Act towards the bank deposits and further INR 9,60,568/- added as unexplained income being difference between deposits and income declared ... whether the CIT (A) was justified to cancel the additions made on account of deposits made into bank accounts which have been treated as unexplained money in the hands of the assessee u/s 69A of the I.T. Act and have been added to the total income of the assessee which