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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

Babli Devi, Village Narla, P.O. Kunnu vs. Income Tax Officer, Aayakar Bhawan, Bhiuli

The appeal stand partly allowed in terms of our above order

ITA 157/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh21 Apr 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.157/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2017-18) Ms. Babli Devi Ito, Mandi (D/O Mool Singh) बनाम/ District Mandi Village Narla, P.O.Kunnu, Tehsil Padhar Hp-175001. Vs. District Mandi (Hp) 175012 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Blepd-5225-Q (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Gaurav Thakur, (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 08-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-04-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2017-18 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 07-09-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 147 R.W.S. 144B Of The Act On 27-03-2022. The Sole Grievance Of The Assessee Is Confirmation Of Addition Of Cash Deposit For Rs.32.53 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

For Appellant: Sh. Gaurav Thakur, (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 147Section 69A

purchase goods from state civil supplies corporation and sold the same to customers covered under PDS scheme. However, Ld. AO added the deposits as unexplained money u/s 69A. The Ld. CIT(A) did not admit the appeal for want of condonation of 118 days. Aggrieved, the assessee is in further

Vijay Lakshmi Mittal, Ludhiana vs. Income Tax Officer, Ludhiana

The appeal stands allowed

ITA 816/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh21 Apr 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.816/Chandi/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Ms. Vijay Lakshmi Mittal Ito, Ward No. 7(5), House No. 123, Green Park Civil Ludhiana - 141001 बनाम/ Vs. Lines, Ludhiana. 141001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abmpm-0926-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Sh. Ashwani Kumar (Ca) & Ms Deepali Aggarwal (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 09-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-04-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2017-18 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 29-11-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 30-12-2019. The Only Dispute In The Appeal Is Applicable Rate Of Tax. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed- Off As Under.

For Appellant: Sh. Ashwani Kumar (CA) &For Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 115BSection 143(3)Section 69A

stated to be deposited in her bank account during demonetization. The Ld. AO rejected the submissions of the assessee and assessed the deposits as unexplained money u/s 69A which would be subjected to higher rate of tax u/s 115BBE. The Ld. CIT(A) confirmed the assessment against which the assessee

Sanghamitra Hazra, Burdwan vs. I.T.O., Ward - 1(4), Burdwan

In the result, appeal of the assessee is allowed

ITA 1176/KOL/2024[2017-2018]Status: DisposedITAT Kolkata21 Apr 2025AY 2017-2018

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.1176/Kol/2024 (नििाारण वर्ा / Assessment Years : 2017-2018) Sanghamitra Hazra, Vs Ito, Ward-1(4), Burdwan C/O S.N.Ghosh&Associates,Advs 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Afmph 2536 K (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररतीकीओरसे /Assessee By : Shri Somnath Ghosh & Shri Sarnath Ghosh, Advocates राजस्वकीओरसे /Revenue By : Ms. Madhumita Das, Addl.Cit सुनवाई की तारीख / Date Of Hearing : 17/04/2025 घोषणा की तारीख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 23.02.2024, Passed By The Ld. Addl./Jcit(A)-2, Ludhiana, For The Assessment Year 2017-2018. 2. At The Outset, On Perusal Of The Appeal Record, It Is Found That The Appeal Of The Assessee Is Filed Belatedly By 29 Days. Looking To The Facts & Circumstances Of The Case, We Condone The Delay Of 29 Days In Filing The Present Appeal On Being Delayed For Genuine & Bonafide Reasons. The Appeal Of The Assessee Is Admitted For Hearing. 3. The Only Issue Raised In This Case Is Against Confirmation Of Addition Of Rs.6,37,363/- By The Ld. Cit(A) As Made By The Ao U/S.69A Of The Act In Respect Of Unexplained Money. 4. Facts In Brief Are That The Assessee Filed The Return Of Income Which Was Selected For Scrutiny For The Reason Of ‘Large Cash Deposits In Bank

For Appellant: Shri Somnath GhoshFor Respondent: Ms. Madhumita Das, Addl.CIT
Section 69A

confirmation of addition of Rs.6,37,363/- by the ld. CIT(A) as made by the AO u/s.69A of the Act in respect of unexplained money. 4. Facts in brief are that the assessee filed the return of income which was selected for scrutiny for the reason of ‘large cash ... accepted the cash deposited in the bank account to be sales proceeds however added the unsecured loans taken by the assessee from relatives as unexplained money u/s.69A of the Act. In the appellate proceedings, the ld. CIT(A) confirmed the order of the ld. AO on this issue. 5. After

ACIT, New Delhi vs. Neeraj Aggarwal, New Delhi

The appeal of the Revenue is dismissed

ITA 3980/DEL/2024[2016]Status: DisposedITAT Delhi21 Apr 2025

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2016-17 Acit, Vs Neeraj Aggarwal, Central Circle-17, Rz-227B, Sadh Nagar, New Delhi. Gali No.6, Palam Colony, New Delhi – 110 045. Pan: Afnpa1136K (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Ms Bhavya Garg, Advocate Revenue By : Shri Sunil Kumar Yadav, Cit-Dr Date Of Hearing : 21.04.2025 Date Of Pronouncement : 21.04.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 10.06.2024 Of The Commissioner Of Income-Tax (Appeals)-31, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Cit(A), Delhi-31/10297/2019-20 Arising Out Of The Appeal Before It Against The Order Dated 29.12.2017 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle-17, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Shri Sunil Kumar Yadav, CIT-DR
Section 143(3)Section 68Section 69A

appellant. 21. Therefore, It is held that the Assessing Officer was not justified in treating the loan of Rs.3 Crores received in cash as unexplained money u/s 3 69A of the appellant. Accordingly, the amount of Rs.3 Crores added by the Assessing Officer is deleted.” 4. However, the ld.CIT ... sustained the addition of the interest of Rs.5,65,000/- as unexplained money and made an addition u/s 69C of the Act. 5. After going through the aforesaid observations of the ld.CIT(A), we are of the considered view that the Revenue does dispute that there was counter entry scribed

Selvi, Trichy vs. Income Tax Officer, Ward 1(2), Trichy

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

ITA 119/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 119/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Ms. Selvi, The Income Tax Officer, 30, North Street, Ward 1(2), Rockfort, Vs. Trichy. Trichy – 620 002. Pan: Aljps 2284C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri P. Thangaraj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.04.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.04.2025 आदेश /O R D E R Per S.R. Raghunatha, Am: This Appeal Of The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi Dated 19.11.2024 For The Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:- I. The Order Of The Learned Assessment Officer Is Against The Law, Weightage Of Evidence & All Probabilities Of The Case.

For Appellant: Shri P. Thangaraj, AdvocateFor Respondent: Ms. Anitha, Addl.CIT

collect the SBN during the demonetisation period, the AO concluded the assessment by making an addition of Rs.6,79,000/- as unexplained money u/s.69A r.w.s. 115BBE of the Act by passing an order u/s.143(3) of the Act dated 26.12.2019. ITA. No:119/Chny/2025 Aggrieved by the order ... accounts of the assessee and further the same have not been rejected. In this scenario making an addition of Rs.6,79,000/- 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 the action

Assistant Commissioner of Income Tax Ltu Circle 1 Chennai, Chennai vs. E I D Parry India Limited, Chennai

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3251/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Apr 2025AY 2012-13

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(1)Section 143(2)Section 250Section 92BSection 92C

assessee carried the matter in appeal before the CIT(A) against the disallowance of depreciation of ₹.1,04,34,735/- and addition of unexplained money of ₹.55,00,000/-. After considering the submissions of the assessee, the CIT(A) confirmed the disallowance of claim of depreciation and the disallowance made ... receipt of ₹.55 lakhs on account of accommodation entries was rightly treated as IT(TP)A Nos.105 to 107/Chny/2024 & ITA No. 3113 & 3251/Chny/24 unexplained money under section 69A of the Act and prayed that the ground raised by the assessee may be dismissed. 28. We have heard both the sides