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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

Pragnaben Jayeshbhai Patel, Surat Gujarat vs. Income Tax Officer, Surat

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 885/SRT/2024[2011-12]Status: DisposedITAT Surat17 Feb 2026AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.885/Srt/2024 िनधा"रण वष" /Assessment Year : 2011-12 बनाम/ Pragnaben Jayeshbhai Patel The Ito V/S. 71, Satyanarayan Society Ward-2(3)(3) Dindoli Surat Surat – 394 210 "थायी लेखा सं./Pan: Bcvpp 2891 Q (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Krutarth Desai, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख /Date Of Pronouncement: 17/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 20/06/2023 For The Assessment Year (Ay) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. In The Facts & Circumstances Of The Case, The Learned Assessing Officer Has Erred In Make An Addition Of Rs. 15,00,000/- Without Having Any Foundational Facts Which Leads To Reason To Believe That Income Has Escaped Assessment. It Is The Settled Position Of Law That Only Cash Deposit Is Not The Ground Of Initiating Assessment As The Same Is Nothing But The Inquiry By The Learned Assessing Officer & Therefore, Notice Issued Under Section 148 Deserves To Be Quashed & Set Aside. Pragnaben Jayeshbhai Patel Vs. Ito Asst. Year : 2011-12

For Appellant: Shri Krutarth Desai, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 143(3)Section 144Section 147Section 148Section 69A

proceedings u/s 144 of the Act were completed by the AO passing order dated 31/08/2018 wherein the addition of Rs.15.00,000/- was made as unexplained money u/s 69A of the Act. 4. During the appellate proceedings before the Ld. CIT(A)e, the assessee contended that source of cash deposits

Karadi Path Education Company Private Limited, Chennai vs. Commissioner, Chennai

ITA 1848/CHNY/2025[2018-2019]Status: DisposedITAT Chennai17 Feb 2026AY 2018-2019

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1848/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Karadi Path Education Company Private Limited, 3A No.11, Dev Regency, I Main Road, Gandhi Nagar, Adyar, Chennai - 600 020. [Pan: Aaeck-2995-D] (अपीलार्थी/Appellant) Dcit, Vs. Corporate Circle -4(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Pradhan Priya Dass, C.A. (By Virtual) प्रत्यर्थी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 27.11.2025 घोषणा की तारीख/Date Of Pronouncement : 17.02.2026 आदेश /O R Der Per S. R. Raghunatha, Am: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short “Ld.Cit(A)”) For The Assessment Year 2018-19, Dated 29.04.2025 In Respect Of The Order Of The National E-Assessment Centre, Delhi (In Short 'Ao') Passed U/S.143(3) Of The Income Tax Act, 1961 ( In Short ‘The Act') Dated 28.04.2021. :-2-:

For Appellant: Shri. Pradhan Priya Dass, C.A. (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(3)Section 56(2)(vii)Section 56(2)(viib)

unaccounted monies. It is evident that the provision was not meant to disturb genuine, bona fide business transactions but to curb tax abuse through unexplained money inflows. In the instant case, neither the AO nor the Id. CIT(A) have held or alleged that unaccounted money has been introduced