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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

Anil Kumar Gupta, Delhi vs. ITO, Ward 49(3), New Delhi

In the result, appeal of the assessee is dismissed

ITA 2112/DEL/2023[2019--20]Status: DisposedITAT Delhi28 May 2025

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.2112/िद"ी/2023(िन.व. 2019-20) Anil Kumar Gupta, 159/161, 2Nd Floor, Katra Baryan, Chandni Chowk, Delhi 110006 ...... अपीलाथ"/Appellant Pan: Aakpg-3803-F बनाम Vs. Income Tax Officer, Ward 49(3), ..... "ितवादी/Respondent Civic Centre, New Delhi 110002 Assessee By : None Department By : Shri Ashish Tripathi, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 03.03.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 28.05.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-27, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 30.05.2023, For Assessment Year 2019-20. 2. Brief Facts Of The Case As Emanating From Records Are: A Search & Seizure Operation U/S. 132 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) Was Conducted In Fakir Chand Lockers & Vaults Pvt. Ltd. On 14.12.2018 The Assessee Was Having One Of The Lockers I.E Locker No. 245 At 6704A Khari Baoli, Delhi. The Aforesaid Locker Was Also Covered Under Search & Seizure

For Appellant: NoneFor Respondent: Shri Ashish Tripathi, Sr. DR
Section 132Section 142(1)Section 143(3)Section 69A

rejected the explanation furnished by the assessee and made addition of Rs.18,50,000/- u/s. 69A r.w.s 115BBE on account of unexplained money. Aggrieved by the assessment order dated 16.06.2021 passed u/s. 143(3) of the Act, the assessee filed appeal before the CIT(A). The assessee reiterated his contentions

Pawapuri Rice Mill Pvt. Ltd, Nalanda vs. ITO, Ward-2(1), Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 636/PAT/2024[2015-16]Status: DisposedITAT Patna27 May 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 634/Pat/2024 Assessment Year: 2013-2014 & I.T.A. No. 635/Pat/2024 Assessment Year: 2014-2015 & I.T.A. No. 636/Pat/2024 Assessment Year: 2015-2016 Pawapuri Rice Mill Pvt. Limited,……..……..Appellant Pokhapur, Pawapuri, P.S. Giriyak, Nalanda-803115, Bihar [Pan:Aagcp6179C] -Vs.- Income Tax Officer,…………………….………...Respondent Ward-2(1), Patna, Bihar Appearances By: No N E, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 05, 2025 Date Of Pronouncing The Order: May 27, 2025 O R D E R Per Duvvuru Rl Reddy, Vice-(Kz):- The Present Three Appeals Bearing Ita Nos. 634/Pat/2024, 635/Pat/2024 & 636/Pat/2024 Are Directed At The Instance Of Assessee Against The Orders Of Ld. Commissioner Of Income Tax

Section 147Section 69A

added this amount of Rs.8,93,87,733/- to the total income of the assessee under section 69A of the Income Tax Act as unexplained money in the hands of assessee. Finally, ld. Assessing Officer assessed income of the assessee for the assessment year 2013-14 at Rs.9 ... Officer added this amount of Rs.68,78,307/- to the total income of the assessee under section 69A of the Income Tax Act as unexplained money in the hands of assessee. Finally, ld. Assessing Officer assessed income of the assessee for the assessment year 2014-15 at Rs.68

Pawapuri Rice Mill Pvt. Ltd, Nalanda vs. ITO, Ward-2(1), Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 635/PAT/2024[2014-15]Status: DisposedITAT Patna27 May 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 634/Pat/2024 Assessment Year: 2013-2014 & I.T.A. No. 635/Pat/2024 Assessment Year: 2014-2015 & I.T.A. No. 636/Pat/2024 Assessment Year: 2015-2016 Pawapuri Rice Mill Pvt. Limited,……..……..Appellant Pokhapur, Pawapuri, P.S. Giriyak, Nalanda-803115, Bihar [Pan:Aagcp6179C] -Vs.- Income Tax Officer,…………………….………...Respondent Ward-2(1), Patna, Bihar Appearances By: No N E, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 05, 2025 Date Of Pronouncing The Order: May 27, 2025 O R D E R Per Duvvuru Rl Reddy, Vice-(Kz):- The Present Three Appeals Bearing Ita Nos. 634/Pat/2024, 635/Pat/2024 & 636/Pat/2024 Are Directed At The Instance Of Assessee Against The Orders Of Ld. Commissioner Of Income Tax

Section 147Section 69A

added this amount of Rs.8,93,87,733/- to the total income of the assessee under section 69A of the Income Tax Act as unexplained money in the hands of assessee. Finally, ld. Assessing Officer assessed income of the assessee for the assessment year 2013-14 at Rs.9 ... Officer added this amount of Rs.68,78,307/- to the total income of the assessee under section 69A of the Income Tax Act as unexplained money in the hands of assessee. Finally, ld. Assessing Officer assessed income of the assessee for the assessment year 2014-15 at Rs.68

Pawapuri Rice Mill Pvt. Ltd, Nalanda vs. ITO Ward, 2(1), Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 634/PAT/2024[2013-14]Status: DisposedITAT Patna27 May 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 634/Pat/2024 Assessment Year: 2013-2014 & I.T.A. No. 635/Pat/2024 Assessment Year: 2014-2015 & I.T.A. No. 636/Pat/2024 Assessment Year: 2015-2016 Pawapuri Rice Mill Pvt. Limited,……..……..Appellant Pokhapur, Pawapuri, P.S. Giriyak, Nalanda-803115, Bihar [Pan:Aagcp6179C] -Vs.- Income Tax Officer,…………………….………...Respondent Ward-2(1), Patna, Bihar Appearances By: No N E, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 05, 2025 Date Of Pronouncing The Order: May 27, 2025 O R D E R Per Duvvuru Rl Reddy, Vice-(Kz):- The Present Three Appeals Bearing Ita Nos. 634/Pat/2024, 635/Pat/2024 & 636/Pat/2024 Are Directed At The Instance Of Assessee Against The Orders Of Ld. Commissioner Of Income Tax

Section 147Section 69A

added this amount of Rs.8,93,87,733/- to the total income of the assessee under section 69A of the Income Tax Act as unexplained money in the hands of assessee. Finally, ld. Assessing Officer assessed income of the assessee for the assessment year 2013-14 at Rs.9 ... Officer added this amount of Rs.68,78,307/- to the total income of the assessee under section 69A of the Income Tax Act as unexplained money in the hands of assessee. Finally, ld. Assessing Officer assessed income of the assessee for the assessment year 2014-15 at Rs.68