“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

Sabirhusen Rasulbhai Malek, Surat vs. ITO, Ward 2(1), Bharuch

In the result, appeal of the assessee is dismissed

ITA 468/SRT/2024[2017-18]Status: DisposedITAT Surat29 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.468/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Sabirhusen Rasulbhai Malek Vs. The Ito, Indian Oil Pump, Devaliya Ward - 2(1), Narmada, Devaliya So - 391121 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aoppm9978Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Kinjal V. Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 17/02/2025 Date Of Pronouncement 29/04/2025

Section 143(2)Section 250Section 270ASection 69A

added Rs.6,00,000/- u/s 69A of the Act. The impugned amount of Rs.6,00,000/- is not the turnover of the assessee but unexplained money found in his possession. Therefore, the ground is also dismissed. 9. In the result, appeal of the assessee is dismissed. Order is pronounced under

Yoosuf Valiya Parambath, Kannur vs. Income Tax Officer Ward 1 and Tps, Kannur

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

ITA 811/COCH/2024[2017-18]Status: DisposedITAT Cochin29 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Year: 2017-18 Yoosuf Valiya Parambath .......... Appellant Valiya Parambath House, Palathai Panoor, Kadavathur, Kannur 670676 [Pan: Apkpv6497B] Vs. The Income Tax Officer .......... Respondent Ward - 1 & Tps, Kannur Appellant By: Shri Narendra Sharma, Advocate Respondent By: Shri Omanakuttan, Sr. Dr Date Of Hearing: 19.03.2025 Date Of Pronouncement: 29.04.2025

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Omanakuttan, Sr. DR

Section 139(1)Section 142(1)Section 143Section 148Section 250(6)Section 69A

144B of the Act on 19.03.2022 at a total income of Rs. 1,58,86,668/-. While doing so, the AO made addition of unexplained money of Rs. 1,58,86,688/- u/s. 69A of the Act. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide

Gulabsingh Raghuwanshi HUF, Indore vs. Income Tax Office 2(5), Indore

ITA 528/IND/2024[2017-18]Status: DisposedITAT Indore29 Apr 2025AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 250Section 253

source of cash deposits in his bank accounts and treated the amount of Rs.28,60,000/- so deposited in above bank accounts as unexplained money u/s 69A r.w.s.115 BBE of the Act and added back the said amount to the total returned income of the assessee

Income Tax Officer Ward 321 Ahmedabad, Ahmedabad vs. Panchanbhai Muljibhai Chavda, A Vinzuvada Mandal

In the result, the appeal filed by the revenue is dismissed

ITA 1951/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad29 Apr 2025AY 2017-18

Bench: Ms. Suchitra Kamble , Judicial & Shri Makarand V. Mahadeokarassessment Year 2017-18

For Appellant: Shri Chirag Shah, A.RFor Respondent: Shri B.P. Srivastava, Sr. D.R

Section 115BSection 139Section 142(1)Section 150Section 292BSection 69A

deposits made in the old currency. Since the assessee has not responded, the Assessing Officer made addition of Rs. 1,47,28,204/- as unexplained money u/s. 69A of the Act. The Assessing Officer further taxed the said amount u/s. 115BBE of the Act @ 60%. 4. Being aggrieved

Shaikh Najeeb Shaikh Abdul Hameed, Jalna vs. Income Tax Officer, Ward 2, Ahmednagar

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

ITA 664/PUN/2025[2018-19]Status: DisposedITAT Pune29 Apr 2025AY 2018-19

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.664/Pun/2025 िनधा"रण वष" / Assessment Yea: 2018-19 Shaikh Najeeb Shaikh Abudul V The Income Tax Officer, Hameed, S Ward-2, Ahmednagar. Naaz Press, Dukhi Nagarm, Street No.2, Old Jalna-431203. Maharashtra. Pan: Eipps2336E Appellant/ Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 151ASection 250Section 69A

learned Commissioner of Income Tax (Appeal), NFAC has erroneously upheld the addition made by the Assessing Officer of Rs. 13.48.200/- being unexplained money u/s 69A of the Income Tax Act, 1961 in the hands of the assessee. 4. On the facts and in the circumstances of the case

Sujatha Kancharla, Hyderabad vs. DCIT., Circle 6(1), Hyderabad

ITA 1233/HYD/2024[2017-2018]Status: DisposedITAT Hyderabad29 Apr 2025AY 2017-2018

Bench: Us:

For Appellant: Shri Pawan KumarFor Respondent: Dr.Sachin Kumar, Sr.DR

Section 143(2)Section 143(3)Section 234BSection 69A

case. 3. Whether the learned Authorities below are justified in making of addition of an amount being Rs. 76,50,000/-as unexplained money under section 69A of the Act, under the facts and circumstance of case. 4. Whether the learned Authorities below are justified in disallowing the expenditure amounting ... lacs (supra) and held the balance amount of Rs.76.50 lacs [Rs.96 lacs (–) Rs.19.50 lacs] as having been sourced out of her unexplained money u/s 69A of the Act. 5. Also, the A.O. while framing the assessment called upon the assessee to provide the ledger extracts of the expenditure that were

Sima Dhara, Kismat Apurbapur vs. Income Tax Officer, Aayakar Bhawan, Chinsurah

The appeal of the assessee is allowed for statistical purposes

ITA 1225/KOL/2023[2017-18]Status: DisposedITAT Kolkata29 Apr 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1225/Kol/2023 Assessment Year: 2017-18 Sima Dhara………………………...……………………………..….……….Appellant Kismat Apurbapur, Natun Bazar, Singur, Hooghly, W.B. – 712409. [Pan: Admpd1772F] Vs. Ito, Chinsurah……….....……..............................……........……...…..…..Respondent Appearances By: Shri Susanta Kr. Mukherjee, Ar, Appeared On Behalf Of The Assessee. Shri Lovish Shelly, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 28, 2025 Date Of Pronouncing The Order : April 29, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 22.09.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Running A Petrol Pump Under The Proprietorship Concern Of M/S Freedom Fighter Service Station. The Assessee Filed Her Return Of Income For The Assessment Year 2017-18 By Declaring A Total Income Of Rs.34,09,050/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass Followed By Notices Issued U/S 143(2) & 142(1) Of The Act. The Assessment Was Completed U/S 143(3) Of The Act On 15.10.2019 By

Section 143(2)Section 143(3)Section 250Section 40A(3)Section 68Section 69A

passing the appellate order has notably converted the basis of addition of Rs.94,86,000/- from section 68 (unexplained cash credit) to section 69A (unexplained money) without issuing any notice and without giving any opportunity to the assessee to respond in this respect. 4. Dissatisfied with the above order

Rajesswaran Sam, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, the appeal filed by the assessee is allowed

ITA 2489/CHNY/2024[2017-18]Status: DisposedITAT Chennai29 Apr 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Ble

For Appellant: Shri K. Srinandan, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

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

2489/CHNY/2024 accounts of the assessee and further the same have not been rejected. In this scenario making an addition of Rs.24,00,000/- as unexplained money on account of the cash deposit made in SBN during the demonetisation period is not sustainable in law. Therefore, we do not countenance ... tribunal (supra) we are of the considered view that the ld.CIT(A) has erred in confirming addition u/s.69A of the Act as unexplained money in respect of cash deposited in SBN during the demonetisation for the reason that the assessee was prohibited to accept the same. Therefore, we are inclined

Income Tax Officer, Ward 2(1), Thiruvananthapuram vs. Tvm District Mercantile Co-Operative Society, Thiruvananthapuram

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

ITA 702/COCH/2024[2018-19]Status: DisposedITAT Cochin28 Apr 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2018-19

For Respondent: Shri Padmanathan K.V

Section 69A

given any credence to the submission of the assessee and went on to find the entire deposit of cash in the bank accounts, as unexplained money in the hands of the assessee. It is also intriguing that the AO had not rejected the books of accounts of the assessee Society

Rupesh Jaiswal, Indore vs. Income Tax Officer, Indore

ITA 889/IND/2024[2017-18]Status: DisposedITAT Indore28 Apr 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 144

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Late Shri. Madan Mohan Jhawar Through Legal Heir Priya Gilda, Raisen, Madhya Pradesh vs. Income Tax Officer, Raisen, Madhya Pradesh

Appeal is allowed for statistical purpose

ITA 633/IND/2024[2017-18]Status: DisposedITAT Indore28 Apr 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 115BSection 142(1)Section 144Section 234ASection 69A

finding no response from assessee, the AO completed assessment to the best of his judgement treating the deposits of Rs. 26,98,100/- as unexplained money u/s 69A and thereby assessing total income at Rs. 26,98,100/-. Aggrieved, the assessee carried matter in first-appeal ... parte u/s 144 due to non-compliances of various statutory notices issued to assessee. The AO has treated the deposits in bank a/c as unexplained money u/s 69A Page 3 of 8 Late Shri Madan Mohan Jhawar Through legal heir Priya Gilda ITA No. 633/Ind/2024 - AY 2017-18 since

Kath Brothers, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 77/JPR/2025[2019-20]Status: DisposedITAT Jaipur28 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 115BSection 133ASection 143(2)Section 143(3)Section 145(3)Section 234ASection 69

profession, or capital gains, nor is it income from other sources' because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have ... profession, or capital gains, nor is it income from other sources' because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have

Rachna Varyani, Kanpur vs. Income Tax Officer, Kanpur

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 23/LKW/2023[2011-12]Status: DisposedITAT Lucknow28 Apr 2025AY 2011-12

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2011-12 Smt. Rachna Varyani V. The Income Tax Officer 117, R.N. Block Ward 2(3) Ratan Lal Nagar Kanpur Kanpur Tan/Pan:Aaxpv4296Q (Appellant) (Respondent) Appellant By: Shri Jitendra Kumar Yadav, Advocate Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 23 04 2025 Date Of Pronouncement: 28 04 2025 O R D E R

For Appellant: Shri Jitendra Kumar Yadav, AdvocateFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)

illegal manner; the sum of money deposited by the assessee has been duly explained and is supported with evidence and hence do not represent unexplained money taxable under Section 69A of the Act. 11. BECAUSE, on the facts and in the circumstances of the case, the order passed

Primary Agricultural Cooperative Society Limited Chinna Golkonda, Shamshabad vs. Income Tax Officer, Ward-8(1), Hyderabad

ITA 1262/HYD/2024[2017-18]Status: DisposedITAT Hyderabad28 Apr 2025AY 2017-18

Bench: Us:

For Appellant: Mrs. S. SandhyaFor Respondent: Shri B. Bala Krishna – CIT-DR

Section 142(1)Section 144Section 250Section 80P

accounts aggregating to Rs. 11,16,07,860/-, therefore, the A.O. was constrained to treat the same as having been sourced out of its unexplained money under Section 69A of the Act. Accordingly, the A.O. vide his order passed u/s 144 of the Act, dated 04.12.2019 determined the income

Asok Sparks, Virudhunagar vs. ACIT, Circle-1, Virudhunagar

In the result, the appeal filed by the assessee is allowed

ITA 93/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 93/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 M/S. Asok Sparks, The Acit, 468, Pks Arumugandar Road, Circle 1, Vs. Sivakasi, Virudhunagar. Virudhunagar – 626 189. [Pan: Aaufa-8489-K] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Anitha, Addl.CIT

Section 143(1)Section 143(3)Section 68Section 69A

having not examined / rejected the books of accounts including the VAT returns, which were made available at every stage of proceedings, the presumption of unexplained money should be reckoned as wholly unjustified and not sustainable in law. 6. The NFAC, Delhi failed to appreciate that in any event having ... December 2016. The assessee has claimed that the above SBN was received from customers. The AO has made an addition of Rs.32.00 Lakhs as unexplained money u/s.69A of the Act stating that the assessee was prohibited to transact in SBN as per the demonetisation notification of w.e.f 09.11.2016 and passed

Emerald Alchymicus Private Limited, Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, above captioned appeals filed by the assessee are allowed for statistical purposes

ITA 1424/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Apr 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Sri Pankaj Soni, Adv a/w Ms. S. Shanmugam,ARsFor Respondent: Sri Biswanath Das, (CIT DR)

Section 147Section 148Section 148ASection 14ASection 270ASection 68Section 69A

depositing cash during demonetisation period without application of mind (vide assessment order dated 24.12.2019). The said amount is treated by the assessing officer as ‘unexplained money’ under section 69A while determining assessed income vide assessment order dated 24.12.2019. 5. That the CIT(A) erred in law and fact in dismissing ... depositing cash during demonetisation period without application of mind. The said amount is treated by the assessing officer as ‘unexplained money’ under section 69A while determining assessed income. 3. That the CIT(A) erred in law and fact in dismissing the appeal of the appellant ex-parte and confirming

Emerald Alchymicus Private Limited, Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, above captioned appeals filed by the assessee are allowed for statistical purposes

ITA 1423/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Sri Pankaj Soni, Adv a/w Ms. S. Shanmugam,ARsFor Respondent: Sri Biswanath Das, (CIT DR)

Section 147Section 148Section 148ASection 14ASection 270ASection 68Section 69A

Emerald Alchymicus Private Limited, Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, above captioned appeals filed by the assessee are allowed for statistical purposes

ITA 1422/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Sri Pankaj Soni, Adv a/w Ms. S. Shanmugam,ARsFor Respondent: Sri Biswanath Das, (CIT DR)

Section 147Section 148Section 148ASection 14ASection 270ASection 68Section 69A

Prabodh Ranjan Dey, Mumbai vs. ITO Ward 28(2)(4), Mumbai

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 6658/MUM/2024[2012-13]Status: DisposedITAT Mumbai28 Apr 2025AY 2012-13

Bench: Shri Narender Kumar Choudhryassessment Year: 2012-13

For Appellant: Ms. Sankriti Dwivedi, Ld. A.RFor Respondent: Shri Manoj Kumar Sinha, Ld. Sr.D.R

Section 250Section 69A

compliance in any of the notices. Consequently, the AO, ultimately made the addition of Rs.24,60,000/- u/s 69A of the Act as unexplained money. 3. The Assessee, being aggrieved, challenged the said addition before the Ld. Commissioner, however, as per impugned order, only submitted the ledger of the different

Sonali Dharmendra Mhatre, Mumbai vs. ITO, WD 3(2), Kalyan

In the result, the appeal filed by the Assessee stands allowed

ITA 6594/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Apr 2025AY 2015-16

Bench: Shri Narender Kumar Choudhryassessment Year: 2015-16

For Appellant: Shri Shashank Mehta, Ld. A.RFor Respondent: Shri Manoj Kumar Sinha, Ld. Sr.D.R

Section 147Section 148Section 148ASection 250

under consideration, and made no addition on such count, however he ultimately made the addition of Rs.17,85,848/- on account of variation qua unexplained money u/s 69A of the Act and Rs.4,17,401/- on account of variation qua income from other sources. 9. The Assessee therefore has claimed