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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

Synergy Auto Inc, Sakinaka Andheri East vs. Income Tax Officer 26 (3) (3), Kautilya Bhavan, Bkc

In the result, the appeal is allowed for statistical purposes

ITA 4752/MUM/2024[2013-2014]Status: HeardITAT Mumbai15 Jan 2025AY 2013-2014

Bench: SHRI NARENDRA KUMAR BILLAIYA (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 143(2)Section 250Section 68Section 69A

assessee’s submissions, learned assessing officer added Rs. 45,00,000/- as unexplained cash credit u/s. 68 of the Act and Rs. 75000/- as unexplained money u/s. 69A of the Act, assessing total income of the assessee at Rs. 52,63,220/-. 3. Aggrieved assessee preferred an appeal before learned

ACIT CC 6(1), Bkc Mumbai vs. Gnp Consultancy and Solutions Private Limited, Thane

Appeal of the revenue is dismissed

ITA 4480/MUM/2024[2018-19]Status: DisposedITAT Mumbai15 Jan 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

expenses of Rs.34,24,58,250/- therefore, the amount of Rs.17,57,00,000/- is treated as unexplained money u/s.69A and the amount of Rs.34,24,58,250/- is treated as unexplained expenditure u/s.69C of the Act. The AO further held that similar addition based on the documents of Shri

ACIT CC -6(1), Mumbai, Bkc vs. Gnp Consultancy and Solutions Pvt. Ltd., Thane

Appeal of the revenue is dismissed

ITA 4479/MUM/2024[2020-21]Status: DisposedITAT Mumbai15 Jan 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

expenses of Rs.34,24,58,250/- therefore, the amount of Rs.17,57,00,000/- is treated as unexplained money u/s.69A and the amount of Rs.34,24,58,250/- is treated as unexplained expenditure u/s.69C of the Act. The AO further held that similar addition based on the documents of Shri

ACIT CC 6(1), Mumbai, Bkc vs. Gnp Cunsultancy and Solutions Pvt. Ltd., Thane

Appeal of the revenue is dismissed

ITA 4478/MUM/2024[2022-23]Status: DisposedITAT Mumbai15 Jan 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

expenses of Rs.34,24,58,250/- therefore, the amount of Rs.17,57,00,000/- is treated as unexplained money u/s.69A and the amount of Rs.34,24,58,250/- is treated as unexplained expenditure u/s.69C of the Act. The AO further held that similar addition based on the documents of Shri

Gnp Consultancy and Solutions Private Limited, Nariman Point, Mumbai vs. DCIT, Circle 6(1), Mumbai

Appeal of the revenue is dismissed

ITA 3432/MUM/2024[2020-21]Status: DisposedITAT Mumbai15 Jan 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

expenses of Rs.34,24,58,250/- therefore, the amount of Rs.17,57,00,000/- is treated as unexplained money u/s.69A and the amount of Rs.34,24,58,250/- is treated as unexplained expenditure u/s.69C of the Act. The AO further held that similar addition based on the documents of Shri

Gnp Consultancy and Solutions Private Limited, Mumbai vs. DCIT, Circle 6 (1), Mumbai

Appeal of the revenue is dismissed

ITA 3430/MUM/2024[2022-23]Status: DisposedITAT Mumbai15 Jan 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

expenses of Rs.34,24,58,250/- therefore, the amount of Rs.17,57,00,000/- is treated as unexplained money u/s.69A and the amount of Rs.34,24,58,250/- is treated as unexplained expenditure u/s.69C of the Act. The AO further held that similar addition based on the documents of Shri

Brij Raj Singh Rathaur, New Delhi vs. Addl. CIT, New Delhi

Appeal is dismissed in above terms

ITA 1762/DEL/2011[2006-07]Status: DisposedITAT Delhi15 Jan 2025AY 2006-07

Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. M. Balaganesh (Accountant Member)

Section 153CSection 68Section 69A

deleting the addition of? 50.00,000/- made by the AO under Section 69A, ignoring the fact that the assessee could not satisfactorily establish the unexplained money in the hands of the assessee. 5. That the appellant craves leave to add, alter, amend, or withdraw any or all ground

Amit Kumar Gupta, Ramanujganj, Balrampur vs. Income Tax Officer-1, Korba

ITA 405/RPR/2024[2011-12]Status: DisposedITAT Raipur13 Jan 2025AY 2011-12

Bench: Shri Ravish Soodआयकर अपील सं. / Ita Nos. 404 & 405/Rpr/2024 "नधा"रण वष" / Assessment Years : 2012-13 & 2011-12 Amit Kumar Gupta House No.7, Shetpara, P.O. Ramanujganj, Dist. Balrampur-497 220 (C.G.) Pan: Axbpg1069P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Korba (C.G.) ……""यथ" / Respondent

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Smt. Anubhaa Tah Goel, Sr. DR
Section 127Section 133(6)Section 142(1)Section 144Section 147Section 148Section 69A

cash deposits of Rs.17,05,824/- in his bank account during the year under consideration, the A.O held the entire amount as his unexplained money u/s. 69A of the Act. Accordingly, the A.O vide his order passed u/s.144 r.w.s. 147 of the Act, dated 16.12.2018 determined the income ... grossly erred in law and facts of the case in treating the entire amount of Rs.17,05,824/- as the assessee’s unexplained money u/s. 69A of the Act. However, the CIT(Appeals) did not find favour with the multi-facet contentions that were advanced by the assessee and upheld

Amit Kumar Gupta, Ramanujganj, Balrampur vs. Income Tax Officer-1, Korba

ITA 404/RPR/2024[2012-13]Status: DisposedITAT Raipur13 Jan 2025AY 2012-13

Bench: Shri Ravish Soodआयकर अपील सं. / Ita Nos. 404 & 405/Rpr/2024 "नधा"रण वष" / Assessment Years : 2012-13 & 2011-12 Amit Kumar Gupta House No.7, Shetpara, P.O. Ramanujganj, Dist. Balrampur-497 220 (C.G.) Pan: Axbpg1069P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Korba (C.G.) ……""यथ" / Respondent

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Smt. Anubhaa Tah Goel, Sr. DR
Section 127Section 133(6)Section 142(1)Section 144Section 147Section 148Section 69A

cash deposits of Rs.17,05,824/- in his bank account during the year under consideration, the A.O held the entire amount as his unexplained money u/s. 69A of the Act. Accordingly, the A.O vide his order passed u/s.144 r.w.s. 147 of the Act, dated 16.12.2018 determined the income ... grossly erred in law and facts of the case in treating the entire amount of Rs.17,05,824/- as the assessee’s unexplained money u/s. 69A of the Act. However, the CIT(Appeals) did not find favour with the multi-facet contentions that were advanced by the assessee and upheld

Ranbir Singh, Sangrur vs. Income Tax Officer, Ward, Sunam

In the result, the appeal of the assessee is allowed

ITA 981/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh13 Jan 2025AY 2017-18

Bench: Us.

For Appellant: Shri Tejmohan Singh, Advocate on behalf of Shri Rishabh Kapoor, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 144Section 69A

cause notice vide notice dated 12.12.20219 which remained uncompiled. Accordingly, the AO concluded the assessment ex-parte making addition of the alleged amount as unexplained money u/s 69A of the Act. 5.4 b) During appellate proceedings, the assessee has filed response vide letter dated 16.05.2022 submitting the appellant

Sunita Bagai, Panchkula vs. Income Tax Officer, Ward-4, Panchkula

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

ITA 947/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh13 Jan 2025AY 2012-13

Bench: The Ld. Cit(A) Who Has Since Sustained The Said Order On Account Of Non-Prosecution.

For Appellant: Shri Aman Parti, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 143(3)Section 69A

Income Tax Act, 1961, vide order dt. 03/12/2019 wherein an amount of Rs. 26,90,000/- has been brought to tax as unexplained money u/s 69A of the Act. Thereafter, the assessee carried 2 the matter in appeal before the Ld. CIT(A) who has since sustained the said order

An American Travel and Tours Pvt. Ltd., Chandigarh vs. Income Tax Officer, Ward-1(3), Chandigarh

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

ITA 63/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh13 Jan 2025AY 2017-18

Bench: The Ld. Cit(A) Who Has Since Sustained The Said Order On Account Of Non-Prosecution On Behalf Of The Assessee.

For Appellant: Ms. Shruti Khandelwal, Advocate for Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl.CIT
Section 144Section 69A

assessment was completed under section 144 vide order dt. 30/11/2019 wherein an amount of Rs. 12,00,000/- has been brought to tax as unexplained money u/s 69A and an amount of Rs 1,86,458/-, being 2% of Rs 93,22,875/- as business income. Thereafter, the assessee carried

Harish Pandey, Raipur vs. ACIT, Circle-1(1), Raipur

ITA 503/RPR/2024[2018-19]Status: DisposedITAT Raipur10 Jan 2025AY 2018-19

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 503/Rpr/2024 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: Shri Yogesh Sethia, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 115BSection 144Section 147Section 148Section 250Section 69A

learned Commissioner of Income Tax (Appeals), NFAC has erred in upholding order of learned Assessing Officer making addition of Rs.87,07,200/- as unexplained money u/s.69A of the Income-tax Act, 1961 and charging the same to higher rate of tax u/s 115BBE of the Act. 4. In the facts ... assessing officer has earned in making addition of Rs. 87,07,200/- U/s 69A of the Income tax Act 1961 unexplained money. 4. In the fact and circumstance of the case and in-law the ld. assessing officer has earned in making of gross contract receipts

M/S Karam Chand Sweets, Zira vs. DCIT, CC-2, Ludhiana

The appeal of the assessee is allowed for statistical

ITA 601/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh10 Jan 2025AY 2019-20

Bench: This Hon'Ble Tribunal. The Assessee Is Aggrieved

For Appellant: None ( Application Rejected)For Respondent: Shri Vivek Vardhan, Addl. CIT
Section 115BSection 133A(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253

Assessing Officer has purely as per his whims and fancies deemed the surrender business income of Rs. 27,18,500.00 as unexplained investments and unexplained money as per section 69 and 69A of Income tax Act, 1961 whereas the Assessee has duly submitted the same as business income over

Sadbhav Engineering Ltd., Ahmedabad vs. DCIT, Central Circle 1(3), Ahmedabad

ITA 235/AHD/2021[2018-19]Status: DisposedITAT Ahmedabad10 Jan 2025AY 2018-19

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarsr. No. Appellant Respondent 1-7 It(Ss)A.No./ Asstt.Year 170 To 175 & 235/Ahd/2021 Asst. Year 2012- 13 To 2018-19 Sadbhav Engineering Ltd. Nr. Havmour Restaurant Navrangpura Ahmedbad. Dcit, Cent.Cir.1(3) Ahmedabad. 8-14 183 To 189/Ahd/2021 Asst. Year 2012- 14 To 2018-19 Pan : Aadcs 0852 Q Dcit, Cent.Cir.1(3) Ahmedabad. Sadbhav Engineering Ltd. Nr. Havmour Restaurant Navrangpura Ahmedabad. (Applicant) (Responent) Assessee By Shri Dhinal Shah, Ar Revenue By: Shri H. Phani Raju, Cit-Dr सुनवाई की तारीख /Date Of Hearing : 18/10/2024 घोषणा की तारीख / Date Of Pronouncement: 10/01/2025 आदेश/Order Per Bench: The Above Cross-Appeals Of The Assessee & The Revenue Are Against The Consolidated Order Of The Ld. Commissioner Of Income Tax(Appeals) 11, Ahmedabad All Dated 04.08.2021 Passed Under Section 250(6) Of The Income Tax Act, 1961 (“The Act" For Short) For The

For Respondent: Shri H. Phani Raju, CIT-DR
Section 115BSection 132Section 139(1)Section 143(3)Section 153ASection 250(6)Section 69ASection 80I

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'A' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT

Santosh Tukaram Varade, Nashik vs. ITO Ward2(1), Nashik

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1928/PUN/2024[2017-18]Status: DisposedITAT Pune10 Jan 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Arvind Desai
Section 148Section 250Section 271(1)(c)Section 271BSection 44ASection 69A

situation prevailed in the A.Y. 2017-18 as well but the AO made the addition of entire credits appearing in the bank accounts as unexplained money u/s.69A at Rs.2,86,93,336/-. 6. At the outset, Ld. Counsel for the assessee submitted that the assessee is an individual engaged

Santosh Tukaram Varade, Nashik vs. ITO Ward 2(1), Nashik

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1927/PUN/2024[2013-14]Status: DisposedITAT Pune10 Jan 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Arvind Desai
Section 148Section 250Section 271(1)(c)Section 271BSection 44ASection 69A

situation prevailed in the A.Y. 2017-18 as well but the AO made the addition of entire credits appearing in the bank accounts as unexplained money u/s.69A at Rs.2,86,93,336/-. 6. At the outset, Ld. Counsel for the assessee submitted that the assessee is an individual engaged

Meena Jewellers Extension Private Limited, Hyderabad vs. ACIT, Circle-5(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 385/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Jan 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.328/Hyd/2024 To 330/Hyd/2024 & Ita 385/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) M/S Meena Jewellers Vs. Acit, Circle-5(1) / Extension Private Limited Circle-16(2) Hyderabad Hyderabad [Pan :Aaicm3013G]

For Appellant: Shri P.Murali Mohan RaoFor Respondent: Shri M.Vijay Kumar, CIT-DR
Section 144Section 250Section 68Section 69A

current liabilities as unexplained cash credits. Similarly, the AO had made addition of Rs.10,83,99,500/-u/s 69A of the Act as unexplained money towards cash deposited in the bank account during the demonetisation period. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before ... appellate proceedings. Therefore, there is no error in the reasons given by the AO to make additions towards cash deposited during demonetisation period as unexplained money u/s 69A of the Act. 6. Aggrieved by the Ld.CIT(A) order, the assessee is now in appeal before the Tribunal. 7. The learned

Meena Jewellers Extension Private Limited, Hyderabad vs. ACIT, Circle-5(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 330/HYD/2024[2018-19]Status: DisposedITAT Hyderabad10 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.328/Hyd/2024 To 330/Hyd/2024 & Ita 385/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) M/S Meena Jewellers Vs. Acit, Circle-5(1) / Extension Private Limited Circle-16(2) Hyderabad Hyderabad [Pan :Aaicm3013G]

For Appellant: Shri P.Murali Mohan RaoFor Respondent: Shri M.Vijay Kumar, CIT-DR
Section 144Section 250Section 68Section 69A

current liabilities as unexplained cash credits. Similarly, the AO had made addition of Rs.10,83,99,500/-u/s 69A of the Act as unexplained money towards cash deposited in the bank account during the demonetisation period. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before ... appellate proceedings. Therefore, there is no error in the reasons given by the AO to make additions towards cash deposited during demonetisation period as unexplained money u/s 69A of the Act. 6. Aggrieved by the Ld.CIT(A) order, the assessee is now in appeal before the Tribunal. 7. The learned

Meena Jewellers Extension Private Limited, Hyderabad vs. ACIT, Circle-16(2), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 329/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Jan 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.328/Hyd/2024 To 330/Hyd/2024 & Ita 385/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) M/S Meena Jewellers Vs. Acit, Circle-5(1) / Extension Private Limited Circle-16(2) Hyderabad Hyderabad [Pan :Aaicm3013G]

For Appellant: Shri P.Murali Mohan RaoFor Respondent: Shri M.Vijay Kumar, CIT-DR
Section 144Section 250Section 68Section 69A

current liabilities as unexplained cash credits. Similarly, the AO had made addition of Rs.10,83,99,500/-u/s 69A of the Act as unexplained money towards cash deposited in the bank account during the demonetisation period. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before ... appellate proceedings. Therefore, there is no error in the reasons given by the AO to make additions towards cash deposited during demonetisation period as unexplained money u/s 69A of the Act. 6. Aggrieved by the Ld.CIT(A) order, the assessee is now in appeal before the Tribunal. 7. The learned