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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

Chauli Singhapur Samabay Krishi Unnayan Samity Ltd., Pashchim Medinipur vs. ACIT, Circle 38, Midnapore

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

ITA 1204/KOL/2025[2017-2018]Status: DisposedITAT Kolkata05 Feb 2026AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Chauli Sighapur Samabay Krishi Unnayan Samity Ltd.……….……….……Appellant Singapur, Chauli, Ghatal, Paschim Medinipur 721212.. [Pan: Aacac0960C] Vs. Acit, Circle-38, Midnapore…………………………..…….....……...…..…..Respondent Appearances By: Shri Amit Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri Santanu Ghosh, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 21, 2026 Date Of Pronouncing The Order : February 05, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 03.04.2025 Of The Nfac, Delhi (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2010–11. 2. Brief Facts Of The Case Are That The Assessee Is A Primary Agricultural Co-Operative Society, Carrying On Business Of Sales Of Fertilisers, Pesticides, Seeds, Providing Loans To Members & Registered Under West Bengal Co-Operative Society Act, 2006. The Assessee Filed Its Income Tax Return For The Assessment Year 2017-18 By Disclosing A Total Income At Rs Nil. The Case Was Selected For Scrutiny Under Cass & Notice U/S 143(2) Of The Act Was Issued. The Assessing Officer Completed The Assessment U/S 143(3) By Denying Deduction Of Rs.29,43,810/- U/S 80P(2) Of The Act & Also Added Back Cash Deposited Rs.24,86,110/- Out Of Total Cash Deposited Rs.2,10,09,000/- During The Period Of Demonetization From 09-11-2016 To 30-12-2016 As Unexplained Money U/S 69A Of The Act.

Section 143(2)Section 143(3)Section 250Section 69ASection 80P(2)

total cash deposited Rs.2,10,09,000/- during the period of demonetization from 09-11-2016 to 30-12-2016 as unexplained money u/s 69A of the Act. 3. Aggrieved by the said order, the assessee filed an appeal before the CIT(A) wherein the ld. CIT(A) partly allowed

Vijayasekar Jeayanthi, Coimbatore vs. ITO, Ncq-2(1), Coimbatore

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

ITA 2683/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Feb 2026AY 2017-18

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2683/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Smt. Vijayasekar Jeayanthi, The Income Tax Officer, 84, Tagore Street, Vs. Non-Corporate Ward 2(1), Sivanandha Colony, Coimbatore Coimbatore -641 012. Pan: Adcpj 7575Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri A. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 05.02.2026

For Appellant: Shri A. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 139Section 142(1)Section 144Section 250Section 251(1)(a)

unable to explain the source of cash deposit to the tune of Rs.50,45,000/-, the AO made addition of Rs.50,45,000/- as unexplained money of the assessee vide order dated 10.12.2019 passed u/s.144 of the Act. 5. Being aggrieved, an appeal was filed before ... that the AO made addition of Rs.50,45,000/- for the alleged failure of the assessee to explain the cash deposits treating it as unexplained money of the assessee. However, it is the contention of the assessee that AO made additions in utter disregard of the submissions made before

Yellayapalem Primary Agricultural Cooperative Society Limited, Nellore vs. ITO, Ward -1, Nellore

In the result, the appeal of the assessee in ITA

ITA 1848/HYD/2025[2015-16]Status: DisposedITAT Hyderabad04 Feb 2026AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1826 & 1848/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19 & 2015-16) Yellayapalem Primary Vs. Income Tax Officer Agricultural Cooperative Ward – 1 Society Ltd, Nellore Nellore Pan:Aaaay2068F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Ramprasad, Ca राज" व "ारा/Revenue By:: Shri A.P. Babu, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 04/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri T. Ramprasad, CAFor Respondent: : Shri A.P. Babu, Sr. DR
Section 147Section 69A

providing credit facilities to its members and that the deposits in bank accounts represent funds of members and business receipts of the society, not unexplained money. 4. The appellant craves leave to add, amend, modify or withdraw any grounds of appeal at the time of hearing.” 3. The brief facts ... providing credit facilities to its members and that the deposits in bank accounts represent funds of members and business receipts of the society, not unexplained money. 4. The appellant craves leave to add, amend, modify or withdraw any grounds of appeal at the time of hearing.” 10. The brief facts

Yellayapalem Primary Agricultural Cooperative Society Limited, Nellore vs. ITO, Ward-1, Nellore

In the result, the appeal of the assessee in ITA

ITA 1826/HYD/2025[2018-19]Status: DisposedITAT Hyderabad04 Feb 2026AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1826 & 1848/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19 & 2015-16) Yellayapalem Primary Vs. Income Tax Officer Agricultural Cooperative Ward – 1 Society Ltd, Nellore Nellore Pan:Aaaay2068F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Ramprasad, Ca राज" व "ारा/Revenue By:: Shri A.P. Babu, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 04/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri T. Ramprasad, CAFor Respondent: : Shri A.P. Babu, Sr. DR
Section 147Section 69A

providing credit facilities to its members and that the deposits in bank accounts represent funds of members and business receipts of the society, not unexplained money. 4. The appellant craves leave to add, amend, modify or withdraw any grounds of appeal at the time of hearing.” 3. The brief facts ... providing credit facilities to its members and that the deposits in bank accounts represent funds of members and business receipts of the society, not unexplained money. 4. The appellant craves leave to add, amend, modify or withdraw any grounds of appeal at the time of hearing.” 10. The brief facts

Jithender Reddy Polu, Nalgonda vs. ITO, Ward-1, Suryapet

In the result, appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 1493/HYD/2025[2017-18]Status: DisposedITAT Hyderabad04 Feb 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1493/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Jithender Reddy Polu, Vs. Income Tax Officer, Nalgonda. Ward-1, Pan:Ahlpp6612R Suryapet. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Nagaraju, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/02/2026 घोषणा की तारीख/Date Of 04/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/01/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 144 Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 05/12/2019 For The Assessment Year (Ay) 2017-18. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri Nagaraju, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 10(1)Section 142(1)Section 144Section 271ASection 69A

Rs.76,98,151/- made in his bank accounts during the subject year, therefore, the entire amount was added by treating it as his unexplained money under section 69A of the Act. 11. We find that the assessee after filing the appeal before the CIT(A) on 06/01/2020