“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

Deputy Commissioner of Income Tax, Central Circle, Delhi-8, Jhandewalan Extension, New Delhi vs. Pooja Mittal, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1336/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Feb 2026AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganeshassessment Year 2014-15 Dcit Vs. Pooja Mittal B-33, Defece Central Circle Colony, Delhi-110024 Delhi Pan No. Ahapm5624K Appellant Respondent Appellant Sh. Om Prakash, Sr. Dr Respondent Sh. Akshat Jain, Ca Sh. Rajat Jain, Ca

Section 133ASection 147Section 148Section 69A

Ld.Commissioner of Income Tax (Appeals)/NFAC dated 05.12.204 for A.Y. 2014-15 in deleting the addition made by the AO on account of unexplained money u/s.69A r.w.s. 115BBE of the Act. 2. Brief facts of the case are that a search and seizure operation was carried out at the premises ... amount received in the books of accounts by the assessee is Rs.40 lacs, the AO treated the balance of Rs.7,20,00,000/- as unexplained money u/s.69A of the Act. 4. On appeal the Ld. CIT(A) deleted the addition on the ground that the agreement to sell was only

Beeraswamy Yogeshwar Mudaliar, Ambikapur vs. ITO, Ward-1, Ambikapur

In the result, appeal of the assessee is allowed

ITA 36/RPR/2026[2013-14]Status: DisposedITAT Raipur16 Feb 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.36/Rpr/2026 "नधा"रण वष" /Assessment Year : 2013-14 Beeraswamy Yogeshwar Mudaliar Ward No.4, Gandhinagar, Veer Sawarkar Marg, P.O. Ambikapur, Dist. Surguja-497 001 Pan: Bnxpm2592L

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 144Section 147Section 148Section 154Section 263Section 271(1)(c)Section 69A

said addition. 6. I am of the considered view that in the original assessment when the amount was added as unexplained money u/s.69A of the Act in the hands of the assessee and thereafter, in the rectification proceedings u/s. 154 of the Act, the Department itself has admitted the validity

Durgawati Panday, Baikunthpur vs. Income Tax Officer Ward No 01, Ambikapur

In the result, appeal of the assessee is allowed

ITA 14/RPR/2026[2020-21]Status: DisposedITAT Raipur16 Feb 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.14/Rpr/2026 "नधा"रण वष" /Assessment Year : 2020-21 Durgawati Panday Ward No.9, Mahalpara, Baikunthpur, Koriya Chhattisgarh-497 335 Pan: Dsipp8404G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward 1, Ambikapur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Prashant Gupta, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 144BSection 147Section 3Section 68Section 69A

Appeals)/NFAC allowed relief of Rs.5 lakhs and sustained the addition of Rs.10 lakhs in the hands of the assessee as unexplained money u/s. 69A of the Act. 4. I am of the considered view that the A.O had applied wrong provisions of the Act i.e. Section ... Section 68 of the Act to the facts of the assessee’s case. Section 69A of the Act on the other hand applies to unexplained money, bullion, jewelry or other valuable article for which the assessee has not furnished any explanation about the nature and source of such money, bullion

Nafishabibi Davji, Surat vs. ITO, Ward 2(3)(3), Surat

ITA 1235/SRT/2025[2017-18]Status: DisposedITAT Surat16 Feb 2026AY 2017-18

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kamble

For Appellant: Shri P M Jagasheth, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 144Section 271ASection 272A(1)(d)Section 69A

reply and therefore the Assessing Officer passed assessment order u/s. 144 of the Act thereby making addition of Rs. 18,30,000/- as unexplained money u/s. 69A of the Act. The Assessing Officer also initiated penalty proceedings u/s. 271AAC(1) and 272A(1)(d) of the Act. I.T.A

Nafishabibi Davji, Surat vs. ITO, Ward 2(3)(3), Surat

ITA 1234/SRT/2025[2017-18]Status: DisposedITAT Surat16 Feb 2026AY 2017-18

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kamble

For Appellant: Shri P M Jagasheth, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 144Section 271ASection 272A(1)(d)Section 69A

Nafishabibi Davji, Surat vs. ITO, Ward 2(3)(3), Surat

ITA 1233/SRT/2025[2017-18]Status: DisposedITAT Surat16 Feb 2026AY 2017-18

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kamble

For Appellant: Shri P M Jagasheth, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 144Section 271ASection 272A(1)(d)Section 69A

Sanketkumar Dipakbhai Vashi, Surat vs. ITO, Ward 5, Navsari

ITA 1092/SRT/2025[2011-12]Status: DisposedITAT Surat16 Feb 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Sapnesh Sheth, AdvocateFor Respondent: Ms. Namita Patel Sr. D.R. & Shri

Section 133(6)Section 142(1)Section 148

assessee. Assessee did not respond the same. Therefore, the Assessing Officer made addition of Rs. 27,62,395/- as unexplained money and further made addition of Rs. 15,66,867/- as credit entries deemed to be income of the assessee for assessment year 2010-11. 3. Being aggrieved

Sanketkumar Dipakbhai Vashi, Na vs. Arivs.ITO, Ward-5, Navsari

ITA 1054/SRT/2025[2011-12]Status: DisposedITAT Surat16 Feb 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Sapnesh Sheth, AdvocateFor Respondent: Ms. Namita Patel Sr. D.R. & Shri

Section 133(6)Section 142(1)Section 148

Choday Janaki Ramayya Chowdary, Visakhapatnam vs. Income Tax Officer, Ward-1, Kakinada

In the result, the appeal filed by the assessee is allowed in terms of my aforesaid observations

ITA 623/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam16 Feb 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble

Section 147Section 148Section 148ASection 69A

cash deposits made in his aforementioned bank account to the extent of Rs. 39,37,000/-, the AO added the same as his unexplained money under section 69A of the Act. Accordingly, the A.O vide his order passed under section 147 r.w.s 144B of the Act, dated 19.02.2024, determined

Jaydev Mahadev Arya, Latur vs. ITO Ward 1, Latur

In the result, all the three appeals filed by the assessee are partly allowed

ITA 1272/PUN/2025[2014-15]Status: DisposedITAT Pune16 Feb 2026AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay D. Kulkarni, Addl.CIT

Section 147Section 148Section 250

assessment order passed u/s 147 r.ws 144 of the ITA, 1961, by treating cash deposited in bank accounts, amount of Rs.32,25,000 as unexplained money u/s 69A of the ITA 1961, without appreciating the nature and source of the deposits and the evidences submitted by the appellant. 2. Appellant

Jaydev Mahadev Arya, Latur vs. ITO Ward 1, Latur

In the result, all the three appeals filed by the assessee are partly allowed

ITA 1271/PUN/2025[2013-14]Status: DisposedITAT Pune16 Feb 2026AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay D. Kulkarni, Addl.CIT

Section 147Section 148Section 250

Income Tax Officer Ward 1, Latur vs. Vimal Jaydev Arya, Latur

In the result, the appeal filed by the Revenue is partly allowed and the CO filed by the assessee is dismissed

ITA 2156/PUN/2024[2015]Status: DisposedITAT Pune16 Feb 2026

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay D. Kulkarni, Addl.CIT

Section 142(1)Section 144Section 147Section 148Section 250Section 69A

Credit Ltd. Since the assessee did not file any reply / evidence, the Assessing Officer treated the cash deposit of Rs.2,47,52,218/- as unexplained money u/s 69A of the Act and determined the total income of the assessee at Rs.2,56,13,494/-. 4. Before ... fact that due to non-response to the statutory notices issued by the Assessing Officer, he made addition of Rs.2,47,52,218/- as unexplained money u/s 69A of the Act being the amount of cash deposited in the bank account maintained with M/s. Renuka Mata Multi State Urban

Petroqo Plastics Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 23(1), Hooghly

In the result, the appeal of the assessee is allowed

ITA 1783/KOL/2025[2017-2018]Status: DisposedITAT Kolkata16 Feb 2026AY 2017-2018

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 143(2)Section 147Section 148Section 250

made by the assessee which di not find favour with /AO , the Assessing Officer made addition of Rs.1,23,50,000/- on account of unexplained money in the assessment framed u/s 147 r.w.s.144B of the /act daste4d 23.03.2022. 3. Aggrieved by the said order, the assessee preferred appeal before

Rajendran Sharmila, Annur vs. Commissioner of Income Tax Appeals, Delhi

In the result, appeal of the assessee is allowed

ITA 2315/CHNY/2025[2017-2018]Status: DisposedITAT Chennai16 Feb 2026AY 2017-2018

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकर अपीलसं./Ita No 2315/Chny/2025 निर्धारणवर्ष/Assessment Year: 2017-18 Rajendran Sharmila 1/66 Main Road, Kariagoundanur Vadakkalur Post, Coimbatore, Tamil Nadu-641653 (अपीलार्थी/Appellant) V. Ito Non Corporate Ward 3(2), Све (प्रत्यर्थी/Respondent) [Pan: Bicps 3272 D] अपीलार्थीकी ओरसे/ Assessee By Mr. K. Muthukumar, Ca प्रत्यर्थीकी ओरसे / Respondent By Mr. C. Sivakumar, Addl.Cit सुनवाईकीतारीख/Date Of Hearing 08.01.2026 घोषणाकीतारीख / Date Of 16.02.2026 Pronouncement आदेश / Order Per Manu Kumar Giri, Jm: This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals) [Cit(A)] Dated 07.07.2025 For The Assessment Year 2017-18, Confirming The Addition Of Rs.70,50,000/- Made By The Ao U/S. 69A Of The Income Tax Act, 1961 (“The Act”).

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

assessee remains unsubstantiated. Accordingly, the addition made by the AOu/s. 69A of the Income-tax Act, 1961, treating the impugned amount as unexplained money, is found to be legally justified. 4. Aggrieved, assessee further challenged the order of the CIT(A) before this Tribunal. 5. The Id.AR for the assessee ... have been accepted as correct. However, while accepting the sales as genuine, the AO has sought to treat the sale consideration received therefrom as unexplained money. He submitted that once the sales and turnover have been accepted, the corresponding sale proceeds cannot be disregarded. The approach adopted

Din Dayal Jalan Textiles Pvt Ltd, Mumbai vs. Asst. CIT 4(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7678/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardin Dayal Jalan Textile Acit-4(1)(1), Pvt. Ltd. Room No. 642, 6Th 904-5, Royal Square, 9Th Vs. Floor, Aayakr Floor, 173, Dr. Vigas Bhavan, Queen Street, Mumbai-400 002 Road, Mumbai – 400 001 Pan/Gir No. Aabcd2310E (Applicant) (Respondent) Assessee By Shri D. C. Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 09.02.2026 Date Of Pronouncement 16.02.2026

Section 132Section 143(3)Section 144BSection 2Section 69A

profession. - Further, for the remaining amount of Rs. 1,00,00,000/-, the Assessing Officer invoked section 69A and treated the same as unexplained money on the ground that the assessee failed to furnish satisfactory explanation regarding the source of such unaccounted cash transaction. 7. Accordingly, the assessment was completed ... emphasized that for the applicability of section 69A, there must be a finding that the assessee is the owner of unexplained money, such money is not recorded in the books of account, and the explanation offered by the assessee is found to be unsatisfactory. It was contended that

Pradeep Sharma, Sagar vs. Assistant Commissioner of Income Tax Circle-1, Katni

The appeal of the assessee is partly allowed

ITA 4/JAB/2024[2017-18]Status: DisposedITAT Jabalpur13 Feb 2026AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 115BSection 133ASection 143(3)Section 154Section 234ASection 250Section 68

provisions, the learned Assessing Officer shall reach a conclusion that the assessee has not offered any explanation about the nature and source of the unexplained money or the explanation offered by him is not to his satisfaction. Therefore, it is only when the learned Assessing Officer requires and records that

Shree Maru Kansara Soni Gnati, Anjar vs. ITO Exemption Ward-1 Rajkot, Rajkot

In the result, appeal filed by the assessee is allowed

ITA 789/RJT/2025[2017-18]Status: DisposedITAT Rajkot13 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 789/Rjt/2025 धििाारण वर्ा/Assessment Year: (2017-18) Shree Maru Kansara Soni Gnati बनाम Income Tax Officer (Exemption), /Vs. C/O Rajesh K Soni, Shashtri Road, Ward- 1, Rajkot, Anjar, Kutch-360 001(Gujarat) It Office, New Aayakar Bhavan,Vatiaka, Rajkot-360 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarts 1920 N (Appellant) (Respondent)

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Gopi Nath Chaubey, Ld. Sr. DR

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 144Section 147Section 148Section 234ASection 250Section 274

without giving proper opportunity of being heard. 4.That, the Ld. AO has wrongly made addition of Rs.30,23,000/- on account of unexplained money u/s 69A of the I.T. Act, 1961. 5. That, the Ld. AO has wrongly applied the provision of section 115BBE

Nilesh Ashanand Thacker, Bhuj vs. ITO Ward 4, Gandhidham (Bhuj)

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

ITA 377/RJT/2025[2012-13]Status: DisposedITAT Rajkot13 Feb 2026AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.377/Rjt/2025 (िनधा"रण वष" /Assessment Year: (2012-13) (Physical Hearing) Nilesh Ashanand Thacker, बनाम Income-Tax Officer, Ward-4, / Near-Laxmi Vekari Mahakali Gandhidham (Bhuj-2)-370 201 Vs. Shopping Mall, Jublee Circle, Bhuj, Kutch-300 001(Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adhpt 8610R (अपीलाथ"/ Appellant) (""थ"/Respondent)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR

Section 143(3)Section 234ASection 250Section 271(1)(c)Section 69A

That the Ld. CIT(A) has wrongly confirmed the addition amounting to Rs.20,36,554/- on account of unexplained money u/s 69A of the I.T. Act, 1961. Nilesh A Thacker 3. That the Ld. CIT(A) has wrongly confirmed initiation of penalty proceedings

Adim Jati Seva Sahakari S Anstha Belkund, Belkund, Betul vs. ITO, Betul

ITA 95/IND/2026[2018-19]Status: DisposedITAT Indore13 Feb 2026AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshisa No. 2/Ind/2026 (Arising Out Of Ita No. 95/Ind/2026) &

Section 139Section 142(1)Section 147Section 148Section 148ASection 250(6)Section 69A

considered assessee's submissions but ultimately made an addition of Rs. 2,31,02,133/- treating the entire amount of impugned deposits as unexplained money u/s 69A r.w.s. 115BBE. Aggrieved, the assessee matter in first-appeal whereupon the CIT(A) dismissed assessee's appeal in limine without adjudicating merits

Sarfarazkhan Sarvarkhan Pathan, Ahmedabad vs. ITO, Ward3(3)(5), Ahmedabad

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

ITA 2016/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P D Shah, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68Section 69Section 69A

Appeal)/ National Faceless Appeal Centre, Delhi has erred in law and facts by confirming the addition amount of Rs.47,48,500/- and treated as unexplained money u/s 69A of the Act, and therefore the learned AO should be directed to delete the impugned addition while computing the total income