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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

The Assistant Commissioner of Income Tax, Central Circle-2, Rajkot vs. Shri Pankaj Chimanlal Lodhiya, Rajkot

In the result, assessee's ground No

ITA 46/RJT/2019[2010-11]Status: DisposedITAT Rajkot28 Mar 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)

Taxman150 wherein the head notes of the case reads as under: “Section 69A, read with section 143 of the Income-tax Act, 1961 -Unexplained moneys - Assessment year 1988-89 - Assessee was a jeweller - During a search carried out at his premises, certain gold ornaments, cash and loose slips containing some

The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot vs. Shri Pankaj Chimanlal Lodhiya, Rajkot

In the result, assessee's ground No

ITA 102/RJT/2019[2014-15]Status: DisposedITAT Rajkot28 Mar 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)

Taxman150 wherein the head notes of the case reads as under: “Section 69A, read with section 143 of the Income-tax Act, 1961 -Unexplained moneys - Assessment year 1988-89 - Assessee was a jeweller - During a search carried out at his premises, certain gold ornaments, cash and loose slips containing some

Palaka Satanarayana, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, both the captioned appeals are disposed of in terms of the aforesaid observations

ITA 282/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam28 Mar 2025AY 2015-16

Bench: Us:

Section 144Section 147Section 148Section 44ASection 69A

Accordingly, the A.O. held the balance amount of cash deposits of Rs.34.50 lacs as having been sourced out of the assessee’s unexplained money u/s 69A of the Act. Accordingly, the Assessing Officer vide his order u/s 147 r.w.s. 144 r.w.s. 144B of the Act, dated 27.03.2022 determined the income

Palaka Satyanarayana, Kakinada vs. Income Tax Office, Ward-1, Kakinada

In the result, both the captioned appeals are disposed of in terms of the aforesaid observations

ITA 281/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam28 Mar 2025AY 2014-15

Bench: Us:

Section 144Section 147Section 148Section 44ASection 69A

Accordingly, the A.O. held the balance amount of cash deposits of Rs.34.50 lacs as having been sourced out of the assessee’s unexplained money u/s 69A of the Act. Accordingly, the Assessing Officer vide his order u/s 147 r.w.s. 144 r.w.s. 144B of the Act, dated 27.03.2022 determined the income

Bhasuram Shopping Private Limited, Neyyattinkara vs. ACIT, Circle-1(1), Trivandrum

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

ITA 139/COCH/2025[2013-14]Status: DisposedITAT Cochin28 Mar 2025AY 2013-14

Bench: Shri Inturi Rama Rao

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Senior AR
Section 143(3)Section 263

that these expenditures were incurred wholly and exclusively for the purpose of business. The AO also made an addition of Rs.11,93,464 as unexplained money of the assessee for failure of the assessee to explain the source of cash deposit of Rs.11,93,464. 3. Being aggrieved, an appeal

Kovvammal Rajesh, Madayi vs. A.O, Assessment Unit, NFAC, Delhi

In the result, the appeal by the assessee is dismissed

ITA 526/COCH/2024[2018-19]Status: DisposedITAT Cochin28 Mar 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Sr.AR
Section 144BSection 147Section 148Section 148ASection 250Section 69ASection 69C

added the total cash deposited amounting to INR 1,07,40,722 total income of the assessee under section 69A of the Act as unexplained money. 4. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee in the absence of any written submission and evidence

Babu Chandrathil George, Palarivattom vs. ITO, Non-Corp Ward-1 (1), Cochin

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

ITA 300/COCH/2024[2016-2017]Status: DisposedITAT Cochin28 Mar 2025AY 2016-2017

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Sr.AR
Section 142(1)Section 143Section 143(2)Section 250Section 69B

barely made submissions, which are contrary to the facts and unsubstantiated by any evidence. Accordingly, the sum of INR 25 lakh was treated as unexplained money in the bank account of the assessee and assessed to tax under section 69B of the Act. 5. The learned CIT(A), vide impugned

Banti Devi, Kotputli vs. ITO War 5(1), Jaipur

In the result, the appeal is hereby dismissed

ITA 1341/JPR/2024[2011-12]Status: DisposedITAT Jaipur28 Mar 2025AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Anand Kumar Gupta, AdvFor Respondent: Shri Gautam Singh choudhary, Addl. CIT a
Section 147Section 148Section 250Section 271(1)Section 69A

quashed. 3. That the action of Ld. Assessing Officer in treating the cash deposit in his saving bank account amounting Rs. 1819628/- as unexplained money in terms of section 69A of the Act is unjust, illogical and arbitrary and deserves to be quashed. 4. That the assessee must be provided

Banti Devi, Kotputli vs. Income Tax Officer Ward 5(1), Jaipur

In the result, the appeal is hereby dismissed

ITA 1326/JPR/2024[2011-12]Status: DisposedITAT Jaipur28 Mar 2025AY 2011-12
For Appellant: Shri Anand Kumar Gupta, AdvFor Respondent: Shri Gautam Singh choudhary, Addl. CIT a
Section 147Section 148Section 250Section 271(1)Section 69A

quashed. 3. That the action of Ld. Assessing Officer in treating the cash deposit in his saving bank account amounting Rs. 1819628/- as unexplained money in terms of section 69A of the Act is unjust, illogical and arbitrary and deserves to be quashed. 4. That the assessee must be provided

Mr. Bharat Natwarlal Dave, Nadiad Kheda vs. ITO Ward 1, Dhule

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

ITA 288/PUN/2025[2013-14]Status: DisposedITAT Pune28 Mar 2025AY 2013-14

Bench: Shri Manish Borad & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.288/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Mr. Bharat Natwarlal Dave, Vs. Ito, Ward-1, Dhule. A/5, Harikunj Society, Opp. Sanket Society, Vaishali Cinema Road, Nadiad Kheda, Gujarat- 387002. Pan : Ahkpd0928P Appellant Respondent Assessee By : Shri Aakash Parakh Revenue By : Shri Manoj Tripathi Date Of Hearing : 20.03.2025 Date Of Pronouncement : 28.03.2025 आदेश / Order Per S. S. Viswanethra Ravi, Jm: This Appeal By The Assessee Against The Order Dated 01.12.2021 Passed By The Cit(A)/Nfac, Delhi For The Assessment Year 2013-14. 2. The Assessee Raised Six Grounds Amongst Which Only Issue Emanates For Our Consideration Is To Whether The Cit(A)/Nfac Justified In Confirming The Addition Made By The Assessing Officer Ex-Parte Of The Assessee.

For Appellant: Shri Aakash ParakhFor Respondent: Shri Manoj Tripathi
Section 144Section 148Section 69A

file of CIT(A)/NFAC. 8. Upon hearing both the parties, we note that the Assessing Officer made addition on account of unexplained money and also computed income in respect of contract receipts with Dhruv Enterprises @ 8%, in our opinion, requires assistance by the assessee in support of his contentions

Lokmanya Gramin Bigar Sheti Sahakari Patsanstha Maryadit Sanli, Sangli vs. ITO Ward5 Sangli, Sangli

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

ITA 2261/PUN/2024[2018-19]Status: DisposedITAT Pune28 Mar 2025AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2261/Pun/2024 िनधा"रण वष" / Assessment Year : 2018-19 Lokmanya Gramin Bigar Vs. Ito, Ward-5, Sangli. Sheti Sahakari Patsanstha Maryadit, At Post 1, Kameri, Walwa, Sangli- 415403. Pan : Aabal0364J Appellant Respondent Assessee By : Shri Sarang Gudhate Revenue By : Shri Chandra Vijay Date Of Hearing : 22.01.2025 Date Of Pronouncement : 28.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Cooperative Society Providing Credit Facilities To Its Members & Has Not Filed Its Return Of Income For The Period Under Consideration. On The Basis Of Information That The Assessee Had Deposited Cash Of Rs.7,47,10,709/-

For Appellant: Shri Sarang GudhateFor Respondent: Shri Chandra Vijay
Section 147Section 148Section 148ASection 69Section 69A

r.w.s. 144 r.w.s. 144B of the IT Act on a total income of Rs.10,05,48,940/-. The above assessed income includes unexplained money u/s 69A of Rs.6,24,88,224/- and unexplained investments u/s 69 of Rs.3,69,21,340/- and undisclosed interest income as income from other sources

Arun Ashar, Mumbai vs. DCIT, Central Circle -2(2), Mumbai

In the result, appeals of the assessee are allowed

ITA 6875/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

For Appellant: Shri Saurabh Soparkar, A/RFor Respondent: Shri Ram Krishn Kedia, Sr. D/R
Section 132(4)Section 69A

addition made u/s 69A of the Act by the AO in respect of cash alleged to have been received by the assessee as unexplained money. 4. Before embarking upon the facts of the case, it would be pertinent to understand the provisions of Section 69A of the Act came ... inserted by the Finance Act, 1964 w.e.f. 01/05/1964 and the same reads as under:- “69A. Unexplained money, etc. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such money, bullion, jewellery or valuable article

Arun Ashar, Mumbai vs. DCIT, Central Circle 2(2), Mumbai

In the result, appeals of the assessee are allowed

ITA 6874/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

For Appellant: Shri Saurabh Soparkar, A/RFor Respondent: Shri Ram Krishn Kedia, Sr. D/R
Section 132(4)Section 69A

addition made u/s 69A of the Act by the AO in respect of cash alleged to have been received by the assessee as unexplained money. आयकर अपीलीय अधिकरण INCOME TAX APPELLATE TRIBUNAL I.T.A. No. 6874 & 6875/Mum/2024 2 4. Before embarking upon the facts of the case, it would be pertinent ... Section 69A of the Act came to be inserted by the Finance Act, 1964 w.e.f. 01/05/1964 and the same reads as under:- "69A. Unexplained money, etc. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such

Nilesh Satish Shingte, Mumbai vs. ITO, Ward-41(3)(3), Mumbai

In the result of the file by the assessee stands partly allowed as indicated hereinabove

ITA 6145/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 132Section 142(1)Section 147Section 148Section 148ASection 151Section 4Section 69A

best of his judgment. The Ld.AO made addition in the hands of the assessee of Rs.50,00,000/- as unexplained money under section 69A of the Act. Aggrieved by the order of the Ld.AO, the assessee preferred appeal before the Ld.CIT(A). 3. The Ld.CIT(A), after considering the submissions

Vineet Thakar, Navi Mumbai vs. ITO(41)(4)(4), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 6098/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Mar 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Prabhash Shankar

For Appellant: Shri Devendra Jain,ARFor Respondent: Ms. Kavitha Kaushik (Sr. DR)
Section 147Section 234ASection 271(1)(c)Section 69A

comprising of salary of Rs.65,37,783/-, interest of Rs.9,97,380/- and Time Deposit of Rs.59,87,858/-, which was treated as unexplained money u/s. 69A r.w.s. 115BBE of the Act. Penalty proceedings u/s 271(1)(c) of the Act were initiated for concealment of income. During this proceeding

Bhinesh Shantilal Desai, Mumbai vs. ITO Ward 24(1)(3), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 4403/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 4403/Mum/2024 (निर्धारण वर्ा / Assessment Year :2017-18) Bhinesh Shantilal Desai V/S. Ito, Ward, 24(1)(3), 401-A, 4Th Floor, Sameer, बिधम Mumbai Off J.P. Road, Seven Room No. 606, Piramal Bunglows, Andheri (W), Chambers, Lalbaug, Parel Mumbai-400058 Mumbai-400012 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadpd3079K Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri P. V. DesaiFor Respondent: Shri Asif Karmali
Section 250Section 69A

bank account with HDFC during the period of demonetization should not be added to the income u/s 69A of the Act as unexplained money. The assessee submitted that he was a full-time salaried employee at till a few years back. Subsequently, he started part-time consultation work

Ullattil Sillu, Kozhikode vs. ITO, Ward 1(4), Kozhikode

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

ITA 131/COCH/2025[2017-18]Status: DisposedITAT Cochin27 Mar 2025AY 2017-18

Bench: Shri Inturi Rama Rao

For Appellant: Sri.P.Raghunathan, AdvocateFor Respondent: Smt.Leena Lal, Senior AR
Section 143(3)Section 250Section 271A

hereinafter). While doing so, the AO made an addition of Rs.2,42,000 being cash deposits made during the demonetization period as unexplained money. Without accepting the explanation of the appellant that the said cash deposit was 2 ITA No.131/Coch/2025. Ullattil Sillu. made out of amount withdrawn on 5th August ... consideration is whether there was justification to sustain the addition of Rs.2,42,000 being the cash deposit made during the demonetization period as unexplained money of the appellant. On mere perusal of the assessment order, it would be clear that the appellant had tendered an explanation that the cash

Thorachiil Varkey Sabu, Ernakulam vs. ITO, Non Corp. Ward-1(4), Ernakulam

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

ITA 935/COCH/2024[2017-18]Status: DisposedITAT Cochin27 Mar 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Thorachiyil Varkey Sabu .......... Appellant Thoraciyil, Mulanthuruthy, Ernakulam 682314 [Pan: Dbgps5503E] Vs. Ito, Non Corporate Ward .......... Respondent C.R. Building, I.S. Press Road Ernakulam 682018

For Appellant: Shri Suresh Kumar Varma, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)

While doing so, the AO made addition of Rs. 38,02,000/- treating the cash deposits in the bank account as unexplained money of the assessee. During the course of assessment proceedings the AO noticed that the appellant made a total cash deposit ... whether the CIT(A) was justified in sustaining the addition of Rs. 38,02,000/- being the cash deposit made in bank account as unexplained money of the appellant. In the grounds of appeal, filed before the CIT(A) the appellant had raised ground of appeal Nos. 2 & 3 explaining

Kajamoideen Mohammed Hashim, Palakkad vs. ITO, Ward-1, Palakkad

In the result, the appeal filed by the assessee stands partly allowed

ITA 864/COCH/2024[2014-15]Status: DisposedITAT Cochin27 Mar 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2014-15 Kajamoideen Mohammed Hashim .......... Appellant 8/351 Kadeeja Manzil, Kadamkode Palakkad 678551 [Pan: Auqpm1241F] Vs. The Income Tax Officer, Ward - 1, Palakkad .......... Respondent

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 56(2)(vii)

total income of Rs. 57,45,110/-. While doing so, the AO made addition of Rs. 53,30,000/- treating the cash deposit as unexplained money of the assessee, rejecting the explanation that the cash deposits were made out of the gift received from his brother, Shri Thanseer Kaja

Pawan Kumar Sharma, Jaipur vs. Income Tax Officer, Jaipur

19. In view of the above discussion, this appeal is disposed of for statistical purposes, and the matter is restored to the files of the Assessing

ITA 76/JPR/2025[2012-2013]Status: DisposedITAT Jaipur27 Mar 2025AY 2012-2013

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Gorav Sharma, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 147Section 69A

hereinafter referred to as “the Act”), by making additions of Rs. 12,14,000/- u/s 69A of the Act, due to unexplained money , and of Rs. 39,70,000/-, because of short term capital gain to the assessee. 3. Assessee challenged above said assessment order, but Learned CIT(A) dismissed