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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

Deputy Commissioner of Income Tax-4(3)(1), Aayakar Bhavan Mumbai vs. Parshwanath Jewellers Private Limited, Mumbai

In the result, appeal of the assessee is partly allowed and appeal of Revenue is dismissed

ITA 4648/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Feb 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri K. Gopal & Ms. Neha Paranjpe, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 69A

confirming the action of the Assessing Officer in making addition of Rs.2,03,00,000/- by treating the cash deposited into bank as unexplained money without appreciating that the Appellant has duly explained the nature and source of the said cash deposits. Thus, the provisions of section ... accounts. Ld. Assessing Officer made the addition of this deposit of cash in bank account by applying provisions of section 69A, treating it as unexplained money. In this respect, it is noted that out of total cash of Rs.2,93,12,972/- during the whole year, cash of Rs.2

Parshwanath Jewellers Pvt Limited, Mumbai vs. Income Tax Officer. Ward 4(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed and appeal of Revenue is dismissed

ITA 4427/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Feb 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri K. Gopal & Ms. Neha Paranjpe, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 69A

confirming the action of the Assessing Officer in making addition of Rs.2,03,00,000/- by treating the cash deposited into bank as unexplained money without appreciating that the Appellant has duly explained the nature and source of the said cash deposits. Thus, the provisions of section ... accounts. Ld. Assessing Officer made the addition of this deposit of cash in bank account by applying provisions of section 69A, treating it as unexplained money. In this respect, it is noted that out of total cash of Rs.2,93,12,972/- during the whole year, cash of Rs.2

Lekha Sreekumar, Mavelikara vs. The Income Tax Officer, Ward-5, Thiruvalla

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

ITA 545/COCH/2024[2017-18]Status: DisposedITAT Cochin21 Feb 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Lekha Sreekumar .......... Appellant Karalil House, Vallikunnam P.O. Mavelikara, Alappuza 690501 [Pan: Alepl6532F] Vs. The Income Tax Officer .......... Respondent Ward - 5, Thiruvalla

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 142(1)

circumstances the AO was constrained to pass best judgement assessment bringing to tax the cash deposit of Rs. 6,75,000/- as unexplained money of the appellant rejecting the explanation of the assessee that out of the said sum of Rs. 4,00,000/- belongs to the appellant’s husband ... India, Pallikkal branch. Out of the total deposit of Rs. 10,00,000/- the AO treated a sum of Rs. 76,75,000 /- as unexplained money of the assessee. While doing so the AO had not accepted the explanation of the appellant that

Soosamma Mullenmadackal Abraham Varghese, Thiruvalla vs. Income Tax Officer Ward-2, Thiruvalla

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

ITA 445/COCH/2024[2015-16]Status: DisposedITAT Cochin21 Feb 2025AY 2015-16

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2015-16

For Respondent: Shri Rachit Thakar
Section 148ASection 69A

raised the following grounds: “1. Learned CIT(A), NFAC, Delhi erred in making additions amounting to Rs.59,59,469/- as unexplained money u/s.69A. 2. Learned CIT(A), NFAC, Delhi erred in making additions amounting to Rs.59,59,649/- as unexplained money Page 2 of 4 deposited in her bank ... therefore the AO based on the information available with him, had made the assessment and treated the said deposits as unexplained money u/s. 69A of the Act. The AO also made an addition since the assessee had not filed any evidences to show that she had paid the taxes

Shilpa Tekkayil, Kozhikode vs. ITO, Ward-1(4), Kozhikode

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

ITA 1162/COCH/2024[2017-18]Status: DisposedITAT Cochin21 Feb 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Shilpa Tekkayil .......... Appellant Sreelakshmi, Kalathil, Thodi Mankavu Kozhikode 673007 [Pan: Ezaps9550N] Vs. The Income Tax Officer .......... Respondent Ward - 1(4), Kozhikode

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 250(6)

total income of Rs. 17,94,242/- after making addition of Rs. 8,90,772/- being cash deposits made during demonetisation period treating as unexplained money of the assessee for the failure of the appellant to explain the source of cash deposits. It is submitted that ... cash balance available on 08.09.2016. On the balance amount of Rs. 8,90,772/- addition was made treating as unexplained money. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO. 4. Being aggrieved, the appellant

Narayanan Dudhachan, Cherai vs. ITO, Non Corporate Ward 2(4) &Tps, Kochi

In the result, the appeal filed by the assessee stands dismissed

ITA 965/COCH/2022[2017-18]Status: DisposedITAT Cochin21 Feb 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Narayanan Dudhachan .......... Appellant Vatheriparambil Veedu Cherai P.O., Ernakulam 683514 [Pan: Awepd4773F] Vs. The Income Tax Officer .......... Respondent Non-Corporate Ward- 2(4) & Tps, Kochi

For Appellant: Ms. Krishna K., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)

being the amount of cash deposited in specified bank notes during demonetisation period in the following bank accounts treating it as unexplained money of the assessee: - Sr. Name of Bank Account Number Total cash deposit No. from 9/11/2016 to 31/12/2016 1 SBI, Cherai Branch ... solitary issue in the present appeal is whether the CIT(A) is justified in confirming the addition of Rs. 10,66,000/- as unexplained money of the appellant. The undisputed facts of the case are that the appellant made a cash deposit of Rs. 17,92,000/- during demonetisation period

Shaiilendra Singh Rajpoot, Bareli vs. ITO, Raisen

Appeal is partly allowed

ITA 462/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18

Bench: Shri B.M. Biyani

Section 133(6)Section 143(2)Section 143(3)Section 69A

made by assessing officer on account of cash deposited in bank account of the appellant, holding it to be unexplained money, invoking Section 69A. The addition made by the assessing officer and confirmed by learned Commissioner (Appeals) is arbitrary, baseless without appreciating facts of the case and is not justified ... could not have been received from customers/cash sales. Therefore, the AO treated the entire deposit of Rs. 11,90,000/- in SBNs as unexplained money u/s 69A (Para 4.1 & 4.2 of assessment-order) and made addition. 6. During first-appeal, the CIT(A) firstly noted that the assessee failed

Sanjeev Agrawal, Bhopal vs. Assistant Commissioner of Income Tax Central-2, Bhopal

Appeal is allowed

ITA 38/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18

Bench: Shri B.M. Biyani

Section 131Section 133ASection 139(1)Section 147Section 148Section 69C

failed to furnish any explanation in this regard. Therefore, a sum of Rs. 10,57,00,000~ is treated as assessee’s unexplained money as per the provisions of sec 69A of I.T. Act and the same is added to the returned income of the assessee

Shri Ram Misra, Sitapur vs. ITO, Sitapur

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

ITA 537/LKW/2024[2017-18]Status: DisposedITAT Lucknow21 Feb 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Shri Ram Misra V. Ito C/O Sanjay Saxena Sitapur 12, Pratap Enclave Bisrat G.T. Road Shahjahanpur Tan/Pan:Adjpm6858Q (Appellant) (Respondent) Appellant By: Shri Sanjay Saxena, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 20 02 2025 Date Of Pronouncement: 21 02 2025 O R D E R

For Appellant: Shri Sanjay Saxena, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 115BSection 142(1)Section 144Section 271ASection 69A

heard, which is liable to be cancelled. 2. That the Id. CIT(A) erred on facts and in law in Rs.10,16,000/- as Unexplained Money deposited in bank account u/s 69A of the Income Tax Act, 1961. 3. That the Id. CIT(A) erred on facts

Vikas Achyutrao Mirajkar, Pune vs. ITO Ward-2, Dhule

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

ITA 1388/PUN/2024[2012-13]Status: DisposedITAT Pune21 Feb 2025AY 2012-13

Bench: Dr.Manish Borad & Ms.Astha Chandraआयकर अपील सं. / Ita No.1388/Pun/2024 िनधा"रण वष" / Assessment Year: 2012-13 Vikas Achyutrao Mirajkar, V The Income Tax Officer, 746/747, Bm Naik Co-Op S Ward-2, Dhule. Hsg Soci., Opp.Food & Drugs Office, Near Panch Haud Church, Guruwar Peth, Pune – 411042. Pan: Afhpm4471M Appellant / Assessee Respondent / Revenue Assessee By Shri Mahavir Jain – Ar Revenue By Shri Arivnd Desai – Addl.Cit(Dr) Date Of Hearing 10/02/2025 Date Of Pronouncement 21/02/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under

Section 143(3)Section 250Section 69A

making addition of Rs.22,50,000/- treating entire amount of advances received towards plot sale from different parties during the year under consideration as unexplained money and income of the appellant u/s. 69A of the Act without considering the facts of the case. 4.1] The Ld. AO failed to appreciate

Assistant Commissioner of Income Tax Central Circle3-(4), Hyderabad vs. Aarthik Greentech Solutions Private Limited, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 32/HYD/2021[2014-15]Status: DisposedITAT Hyderabad21 Feb 2025AY 2014-15

Bench: Shri Manjunatha G. & Shri K.Narasimha Charyआ.अपी.सं /Ita No.32/Hyd/2021 (निर्धारण वर्ा/Assessment Year: 2014-15) Asst.Commissioner Of Vs. Aarthik Greentech Income Tax Solutions Pvt.Ltd. Central Circle-3(4) Hyderabad Hyderabad [Pan : Aalca6887D] आ.अपी.सं /Ita No.33/Hyd/2021 (निर्धारण वर्ा/Assessment Year: 2014-15) Asst.Commissioner Of Vs. Aarthik Infra Projects Income Tax Pvt.Ltd. Central Circle-3(4) Hyderabad Hyderabad [Pan : Aahca0719N] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao,Ar रधजस् व द्वधरध/Revenue By: Ms.M.Narmada, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 19/12/2024 घोर्णध की तधरीख/Date Of 21/02/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: These Appeals Filed By The Revenue Are Directed Against Order Dated 11.09.2020 Of The Commissioner Of Income Tax (Appeals) [“Ld.Cit(A)”]-11, Hyderabad Pertaining To A.Y.2014-15. Since, Facts Are Identical & Issues Are Common, For The Sake Of Aarthik Greentech Solutions Pvt. Ltd. & Aarthik Infra Projects Pvt.Ltd.

For Appellant: Shri P.Murali Mohan Rao,ARFor Respondent: Ms.M.Narmada, CIT-DR
Section 132Section 143(1)Section 153C

proper banking channel, the Ld.CIT(A) observed that the Assessing Officer is erred in making additions towards investment u/s 68 of the Act, as unexplained money and therefore, deleted the additions made by the Assessing Officer. Relevant findings of the Ld.CIT(A) are as under : Aarthik Greentech Solutions

Ramanathan Girish, Salem vs. ITO, Ward 1(6), Salem

ITA 1846/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Feb 2025AY 2012-13
For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Mr. R. Clement Ramesh Kumar, CIT
Section 148Section 69A

absence of jurisdiction for reopening. II MERITS OF ADDITION : 6. The CIT(A) NFAC erred in confirming the addition of Rs.69,75,000/- as unexplained money u/s.69A of the Act. 7. The CIT(A) NFAC failed to appreciate that the cash deposits in the bank accounts was relatable

Sri. D. K Shivakumar, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel
Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

Property Rs. 4,00,00,000/- (6) Unexplained investment made by Mr. Chandrashekhar Sukhapuri on behalf of the Assessee Rs. 50,00,000/- (7) Unexplained money based on material seized from residence of Mr. K Rajendran Rs. 2,30,00,000/- (8) Unexplained money based on material seized from residence ... Assessee Rs. 43,18,00,000/- (9) Unexplained money based on material seized from residence of the Assessee Rs. 28,00,00,000/- (10) Unexplained money based on material seized from residence of the Assessee Rs. 9,26,00,000/- (11) Unexplained money based on material seized from residence

Mrs. Jayashree Subhash Dudhal, Mumbai vs. ITO 27(1)(5), Mumbai

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

ITA 6785/MUM/2024[2017-18]Status: DisposedITAT Mumbai21 Feb 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am Mrs. Jayashree Subhash Dudhal Ito 27(1)(5) 410, 4Th Floor, Tower 6, Vashi, 1801/A, Rayan Park, Bhiwandi Link Vs. Road, Govandi, Mumbai – 400043. Mumbai – 400703. Pan/Gir No. Asppd9987Q (Assessee) : (Respondent) Assessee By : Shri. Gautam Ravaria Respondent By : Shri. P. D. Chougule Sr. Dr. Date Of Hearing : 19.02.2025 Date Of Pronouncement : 21.02.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2017-18. 2. The Assessee Has Challenged This Appeal On The Following Grounds Of Appeal: - “1. On Given Facts, Hon. Cit (Appeals) Erred In Mentioning The Incorrect Assessment Year While Passing The Order. The Appeal Was Filed For Assessment Year (Ay) 2017-18, But The Order Incorrectly States The Assessment Year As Ay 2022-23. 2. On Given Facts, The Assessing Officer Considered My Business Deposits Into My Current & Savings Accounts As Deposits Of Undisclosed Income, Rather Than Recognizing Them As Business Receipts. However, If You Kindly Review My Bank Statements For The Entire Year Or For A Longer Period, You Will See That It Is A Common Practice For Me To Deposit Cash Receipts From Sales.” Mrs. Jayashree Subhash Dudhal

For Appellant: Shri. Gautam RavariaFor Respondent: Shri. P. D. Chougule SR. DR
Section 142(1)Section 147Section 148Section 250Section 69A

where the nature and source of above cash deposit remained unexplained. Therefore, the entire cash deposit of Rs. 12,19,020/- was treated as unexplained money u/s. 69A of the Act. It is observed that the assessee has been non-compliant during the assessment proceeding and the ld. AO passed ... where the ld. AO determined the total income at Rs. 18,24,770/- after making addition of Rs. 12,19,020/- u/s. 69A as unexplained money. 4. Aggrieved the assessee was in appeal before the first appellate authority, who vide an ex parte order dated 09.10.2024 upheld the addition made

Ms Milan Agency, Mumbai vs. ITO Assessement Unit, It Dept

In the result, the appeal of the assessee is allowed

ITA 5414/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Feb 2025AY 2018-19

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singhassessment Year: 2018-19 M/S. Milan Agency Ito, Assessment Unit, It Deptt. Shop No. 6, Friends Shopping Vs. Centre, Azad Road, Andheri East, Mumbai-400069. Pan: Aaefm 8738 P (Appellant) (Respondent) Present For: Assessee By : Shri K. Gopal, Advocate & Om Kandalkar Revenue By : Ms. Monika H. Pande, Sr. Dr

For Appellant: Shri K. Gopal, Advocate & Om KandalkarFor Respondent: Ms. Monika H. Pande, Sr. DR
Section 144BSection 145ASection 147Section 148Section 148ASection 149Section 151Section 274Section 44A

also asked to show cause and explain by such bogus invoices of Rs. 1,07,68,328/- shall not be treated as unexplained money u/s 69 of the Act. However, the AO has not made any discussion verification and examination of this issue in the assessment order. On the other

Abhishek Sanjeev Nadgeri, Navi Mumbai vs. Assessment Unit, Income Tax Department, Navi Mumbai

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

ITA 4499/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai21 Feb 2025

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

Section 115BSection 131Section 147Section 148Section 148ASection 149Section 151Section 69A

erred in treating a sum of Rs. 7,08,336 (being sum admitted by appellant as received against accommodation bills), as unexplained money u/s 69A inspite of explaining the source of money and consequently, subjecting the same to tax at the rates prescribed u/s 115BBE. b. The Ld.AO ... making addition of Rs. 7,47,709/- including income from other sources amounting to Rs.7,08,336/-, treated as unexplained money under section 69A of the Act. Aggrieved by the order of the Ld.AO, assessee preferred appeal before the Ld. CIT(A). 3. Various grounds on merit as well

Vure Naga Mallikarjuna Rao, Vijayawada vs. Income Tax Officer, Ward-2(4), Vijayawada

In the result, appeal filed by the assessee is allowed

ITA 521/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam20 Feb 2025AY 2017-18

Bench: Shri K Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Hybrid Hearing) आयकर अपील सं./ I.T.A. 521/Viz/2024 (निर्धारण वर्ा / Assessment Year: 2017-18) Vure Naga Mallikarjuna Rao, Vs. Income Tax Officer, D.No. 9-1382-1, Ward-2(4), Near Ankamma Thalli Temple, Vijayawada. Kankipadu, Krishna District, Andhra Pradesh-521151. Pan: Aempv1331F (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Assessee By : Sri Mv Prasad, Ar प्रत्यधर्थी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri MV Prasad, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 143(2)Section 143(3)Section 69A

justified in upholding the addition made of Rs. 10,90,000/- by the Assessing Officer U/s. 69A of the Act as unexplained money. 3. The Ld. CIT(A) is not justified in confirming the addition made by the AO even though the sources explained by the appellant that same

M/S Orthopaedics and Trauma Center, Jhalawar vs. DCIT, Central Circle, Kota

25. In view of the above discussion, reasons and findings, this appeal deserves to be allowed

ITA 1444/JPR/2024[2019-20]Status: DisposedITAT Jaipur20 Feb 2025AY 2019-20

Bench: the ld. CIT(A), assessment order dated 2-06-2021 was under challenge. Vide said assessment order, the AO computed total income of the assessee at 1,02,55,230/- by observing in the manner as:-

For Appellant: Shri P.C. Parwal, CAFor Respondent: Sh. Manoj Kumar, JCIT-DR
Section 115BSection 139Section 143(2)Section 143(3)Section 156Section 234BSection 244ASection 250Section 271ASection 274

cash of Rs. 8,28,900/- and excess stock of Rs. 4,68,290/- offered during the survey proceedings are considered as unexplained investment, unexplained money and amount of investments, etc., not fully disclosed in books of account as per provision of section

Amanpreet Kaur L/H of Late Pavittar Kaur Walia, Mohali vs. Income Tax Officer, Ward 6(2), Mohali

In the result, appeal of the assessee is allowed

ITA 877/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh20 Feb 2025AY 2012-13

Bench: Shri Rajpal Yadav

For Appellant: Shri A.K. Sood, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT
Section 144Section 147Section 148

only prosecutor but of adjudicator also. He should have collected the complete information from the Bank and thereafter find out whether any unexplained money was possessed by the assessee or not but he did not carry out any exercise, therefore, I am satisfied that assessee has an explainable source

Smt. Teena Garg, Chandigarh vs. PCIT, Panchkula

In the result, appeal of the assessee is allowed

ITA 466/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh20 Feb 2025AY 2015-16
For Respondent: Shri Sudhir Sehgal, Advocate
Section 142(1)Section 143(2)Section 147Section 148Section 253Section 263

show 'exempt income'. Accordingly the assessee was called explain as to why entire receipt for Rs.29,38,945/- should not be treated as unexplained money u/s 69A of the Act. Thus an opportunity was given to assessee to show cause why proposed variation should not be made and the assessment