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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

K V Tex Firm, Chennai vs. Asst. Commissioner of Income Tax, Chennai

In the result, all the three appeals of the assessee stand allowed

ITA 1860/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Feb 2026AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 132Section 139(1)Section 143Section 147Section 44A

suppressed receipts are found to have been converted into assets, or when there is evidence of retention of the entire sale proceeds as unexplained money, that the total turnover could conceivably represent income. 77. In the present case, no such undisclosed asset, investment, or cash was found during the course

K V Tex Firm, Chennai vs. Asst. Commissioner of Income Tax, Chennai

Appeals of the assessee stand allowed

ITA 1859/CHNY/2025[2021-22]Status: DisposedITAT Chennai04 Feb 2026AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 132Section 139(1)Section 143Section 147Section 44A

suppressed receipts are found to have been converted into assets, or when there is evidence of retention of the entire sale proceeds as unexplained money, that the total turnover could conceivably represent income. 77. Inthe present case, no such undisclosed asset, investment, or cash was found during the course

Muniyappa Nagaraj, Bangalore vs. Income Tax Officer. Ward-4(2)(2), Bangalore

In the result appeal of the assessee allowed for statistical purposes

ITA 1294/BANG/2025[2017-18]Status: DisposedITAT Bangalore04 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Balaram R Rao, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 133(6)Section 142(1)Section 144Section 250

under section 144 of the Act and held that the source of cash deposits remained unexplained. Accordingly, the AO added ₹26,61,500/- as unexplained money under section 69A of the Act being deposits made during the demonetization and further added ₹6,45,040/- as business income being

Tufel, Gurgaon vs. ITO, Ward 4(4), Gurgaon

In the result, the appeal of the assessee in ITA No

ITA 3293/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri M.R. Sahu, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 115BSection 127(2)Section 142(1)Section 143(2)Section 144Section 44ASection 69A

goods carriage, thus the addition of Rs.22,87,991/-confirmed by the CIT(A) may kindly be taxed under normal provisions and not as unexplained money u/s.69A. 3. That the assessee craves the right to amend, add, delete, replace, all or any of the grounds of appeal either during

Neeraj Kumar, Agra vs. Income Tax Officer Ward 2(1)(3), Agra

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

ITA 538/AGR/2025[2011-12]Status: DisposedITAT Agra03 Feb 2026AY 2011-12

Bench: Shri M. Balaganeshneeraj Kumar, Vs. Income Tax Officer, 18/24, Ghadi Hussaini Ward-2(1)(3), Prakash Nagar, Agra Agra (Appellant) (Respondent) Pan: Ajwpn8393C Assessee By : Shri Jitendra Garg, Adv Shri Pradumn Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 03/02/2026

For Appellant: Shri Jitendra Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139Section 144Section 147Section 148Section 154Section 250Section 271(1)(b)Section 44ASection 69A

which no satisfactory explanation was afforded by the Assessee. Hence, the assessment was completed ex parte by adding the said cash deposits as unexplained money under section 69A of the Act. Before the Learned JCIT(A), the Assessee furnished complete details of the bank statement and also submitted that

Rajeev Gupta, Agra vs. Deputy Commissioner of Income-Tax, Central Circle, Agra

In the result, the appeal of the assessee is allowed

ITA 531/AGR/2025[2020-21]Status: DisposedITAT Agra03 Feb 2026AY 2020-21

Bench: Shri M. Balaganeshrajeev Gupta, Vs. Dcit, Mohalla Jai Jai Ram, Gali Central Circle, Nalwali, Kasganj, Agra Agra (Appellant) (Respondent) Pan: Ahfpg8331C Assessee By : Shri Deependra Mohan, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 03/02/2026

For Appellant: Shri Deependra Mohan, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 115BSection 127Section 143(3)Section 153ASection 69A

remaining sum of Rs. 5,50,000 (Rs. 10,00,000 minus Rs. 4,50,000) was sought to be added as unexplained money under section 69A read with section 115BBE of the Act and addition made in the hands of the assessee accordingly in the assessment framed under section

Bikesh Kumar, Firozabad vs. Income Tax Officer 2(2)(1), Firozabad

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

ITA 490/AGR/2025[2013-14]Status: DisposedITAT Agra03 Feb 2026AY 2013-14

Bench: Shri M. Balaganeshbikesh Kumar, Vs. Income Tax Officer, Nagla Bhoop Nasirpur, Ward-2(2)(1), Shikhabad Firozabad, Firozabad Firozabad (Appellant) (Respondent) Pan: Bglpk0327A Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 23/01/2026 Date Of Pronouncement 03/02/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133(6)Section 142(1)Section 147Section 148Section 250Section 250(6)Section 69Section 69A

adding the differential sum of cash deposits and income returned by the assessee in the total sum Rs 24,18,701 as unexplained money under section 69-A of the Act. 4. The assessee gave ground wise submissions before the Learned NFAC which are reproduced in the appellate order itself

Barhattakar Sewa Sahakari Samiti Maryadit Raipur, Raipur vs. ITO-2, Itarsi

Appeal is allowed for statistical purpose, subject

ITA 583/IND/2025[2017-18]Status: DisposedITAT Indore03 Feb 2026AY 2017-18

Bench: Shri B.M. Biyani

Section 147

facts and circumstances of the case. 3. The Id CIT(A) was not justified in confirming the addition of Rs. 62,72,767/ as unexplained money u*%. 69A without considering the facts and circumstances of the case. 4.The appellant carves leave to add, amend OR modify any of the grounds

Bhaumik Jewellers Private Limited, Ahmedabad vs. The ITO, Ward-1(1)(2), Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 1642/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1642/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Bhaumik Jewellers Private The Ito बनाम/ Limited Ward-1(1)(2) V/S. 111, Gold Souk Complex Ahmedabad B/H. Sapphire Complex Cg Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aagcb 2423 B (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 03/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac), Delhi [In Short “The Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 (In Short “The Act”), Dated 26/07/2024 Arising Out Of The Assessment Order Passed By The Assessing Officer (In Short “The Ao”) Under Section 143(3) Of The Act For The Assessment Year 2017-18. The Assessee In This Appeal Has Agitated The Confirmation Of The Addition Of Rs. 9,65,97,834/- Made By The Ao Under Section 68 Of The Act Bhaumik Jewellers Private Limited Vs. The Ito Asst. Year : 2017-18

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 115BSection 133(6)Section 143(3)Section 145(3)Section 250Section 68

demonetized notes after 8.11.2016 in violation of the notifications issued by RBI. Accordingly, he has taken the view that the above said amounts represents unexplained money of the assessee. I am unable to understand the rationale in the view taken by A.O. I noticed that the AO has invoked

Veerappagowder Manoharan Rep. by L/Heir, Erode vs. ITO, Ward-2(1), Erode

In the result, the appeal of the assessee is allowed and the Stay application is dismissed as infructuous

ITA 3627/CHNY/2025[2018-19]Status: DisposedITAT Chennai03 Feb 2026AY 2018-19

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3627/Chny/2025 & Sa No.140/Chny/2025 (Arising In Ita No.3627/Chny/2025) िनधा"रण वष" /Assessment Year: 2018-19 Veerappagowder Manoharan, The Income Tax Officer, 1/48, 2Nd Street Rajan Nagar, Vs. Ward-2(1), Rajan Nagar B.O., Erode. Erode – 638 451. Pan: Brspm 5358P

For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 148Section 148ASection 151Section 250Section 69A

commission @ 0.05% on Rs. 60,00,000/-. Accordingly, the A.O completed the assessment u/s. 147 of the Act treating the entire cash deposit as unexplained money u/s. 69A of the Act. On further appeal, the CIT(A) dismissed the appeal of the assessee on the same ground that the assessee

Deputy Commissioner of Income Tax Central Circle-1(4), Blr, Bengaluru vs. Davanam Constructions Pvt Ltd, Bengaluru

In the result, all the three appeals filed by the revenue are dismissed

ITA 2103/BANG/2025[2018-19]Status: HeardITAT Bangalore03 Feb 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: NoneFor Respondent: Smt. N. Hemalatha, CIT-DR
Section 142(1)Section 143(2)Section 153C

objection that the initiation of proceedings u/s. 153C is valid. Thereafter the assessment has been completed u/s. 153C and addition was made as unexplained money in respect of the refundable deposits. Similarly, the block assessment for the earlier period of six years were also made. In respect

Deputy Commissioner of Income Tax Central Circle-1(4), Ble, Bengaluru vs. Davanam Constructions Pvt Ltd, Bengaluru

In the result, all the three appeals filed by the revenue are dismissed

ITA 2102/BANG/2025[2017-18]Status: HeardITAT Bangalore03 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: NoneFor Respondent: Smt. N. Hemalatha, CIT-DR
Section 142(1)Section 143(2)Section 153C

objection that the initiation of proceedings u/s. 153C is valid. Thereafter the assessment has been completed u/s. 153C and addition was made as unexplained money in respect of the refundable deposits. Similarly, the block assessment for the earlier period of six years were also made. In respect

Deputy Commissioner of Income Tax, Central Circle-1(4), Blr, Bengaluru vs. Davanam Constructions Pvt Ltd, Bengaluru

In the result, all the three appeals filed by the revenue are dismissed

ITA 2101/BANG/2025[2014-15]Status: HeardITAT Bangalore03 Feb 2026AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: NoneFor Respondent: Smt. N. Hemalatha, CIT-DR
Section 142(1)Section 143(2)Section 153C

objection that the initiation of proceedings u/s. 153C is valid. Thereafter the assessment has been completed u/s. 153C and addition was made as unexplained money in respect of the refundable deposits. Similarly, the block assessment for the earlier period of six years were also made. In respect

Reshma Ketan Doshi, Bagalkot vs. Income Tax Officer, Ward-1 & Tps, Bagalkot

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

ITA 1995/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Prasanna, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 115BSection 69A

grounds, the AO held that the explanation furnished by the assessee was not acceptable and treated the cash deposit of ₹27,50,000 as unexplained money under section 69A of the Act, bringing it to tax under section 115BBE of the Act. 6. The aggrieved assessee preferred an appeal before

Rajesh Gujjar, Bagalkot vs. Income Tax Officer, Ward-1 & Tps, Bagalkot

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

ITA 1994/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Prasanna, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 115BSection 69A

grounds, the AO held that the explanation furnished by the assessee was not acceptable and treated the cash deposit of ₹27,50,000 as unexplained money under section 69A of the Act, bringing it to tax under section 115BBE of the Act. 6. The aggrieved assessee preferred an appeal before

Kishorbhai Dattani, Jam Khambhalia vs. Income Tax Officer, Ward -1, Dwarka

In the result, the appeal of the assessee is allowed

ITA 555/RJT/2025[2017-18]Status: DisposedITAT Rajkot02 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 555/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Kishorbhai Dattani Vs. Income Tax Office, Hospital C/O. Sarda & Sarda (Ca), Sakar 1St Road, Near Rajdhani Hotel, Floor, Dr. Radha-Krishnan Road, Dwarka, Gujarat 361335 Opp. Rajkumar College, Rajkot, Rajkot Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakpd7272M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 03 / 11 /2025 Date Of Pronouncement : 02/ 02 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR
Section 115BSection 144BSection 147Section 148Section 250Section 69A

loan given nor furnished any cash flow statement. Hence, the cash loan of Rs. 10,00,000/-advanced by the appellant was treated as unexplained money u/s 69A of the Act. The Kishorbhai Dattani vs. ITO Ward – 1 Dwarka AO completed the assessment on the total income ... substantiate the claimed purchases and cash payments. This weakens the evidentiary value of such statements. The AO has therefore rightly treated the amount as unexplained money within the meaning of section 69A. Accordingly, the addition of Rs. 10,00,000/- u/s 69A is confirmed, and Ground No. 3 is dismissed

Mr. Ashish Ramesh Ajmera, Dhule vs. ITO, Ward 1, Dhule

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

ITA 2506/PUN/2025[2013-14]Status: DisposedITAT Pune02 Feb 2026AY 2013-14

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2506/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Mr.Ashish Ramesh Ajmera, V Income Tax Officer, Plot No.17, Ashish Saraswati S Ward-1, Dhule. Colony, Vidhyanagri, Dhule – 424005 Pan: Aaopa3375J Appellant/ Assessee Respondent /Revenue Assessee By Shri Bhuvanesh Kankani Revenue By Shri Sandeep Sathe – Jcit Date Of Hearing 09/12/2026 Date Of Pronouncement 02/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal), Panaji Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 29.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 147 Of The Act, Dated 14.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 147Section 250Section 69A

added the above cash deposited in the bank account to the returned income for the year by treating the same as unexplained money under section 69A of the Act. The provisions of section 69A of the Act is reproduced as under: "Where in any financial year the assessee is found ... Assessee could not explain the source of cash deposits. In addition to this, Assessing Officer has also made addition of Rs.5,45,377/- as unexplained money. Thus, it can be observed that the additions made in the assessment order of Rs.10 lakhs which was cash deposit

Venkataraman Giridharan, Kancheepuram vs. ITO, Ward-2, Kancheepuram

In the result, the appeal of the assessee is allowed and the stay application is dismissed as infructuous

ITA 3199/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Feb 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. Sonali, &For Respondent: Shri. Guru Prasad, Addl. C.I.T
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 44ASection 69A

that the cash deposit of Rs.20,00,000/- is out of the business i.e. cash sales and as such same cannot be treated as unexplained money. 4. The CIT(A) ought to have appreciated that the Appellant has filed required evidentiary documents such as sales bills, confirmation from Purchasers ... 3199/Chny/2025 been accepted and the books of account have not been rejected, the cash deposits representing such recorded sales receipts cannot be treated as unexplained money. Accordingly, the Ld. AR prayed that the addition made by the AO and sustained by the Ld. JCIT(A) be deleted. 9. Per contra

Kasiredday Ranadheer Reddy, Bengaluru vs. ACIT, Central Circle-2(1), Bangalore

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

ITA 887/BANG/2025[2017-18]Status: DisposedITAT Bangalore02 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

nature of interest earned from money lending activities. The AO made an addition u/s 69 of the Act on account of unexplained money to the tune of Rs. 1,12,00,000 (Rs. 1 Crore principal and Rs. 12 Lakhs interest thereon) based on page 102 of A/ST/KKR/01. 5. Aggrieved ... payment of Rs. 5.5 crores in pursuance to the sale agreement, sources of which were not explained. Hence, the AO treated the same as unexplained money under section 69 of the Act and added to the total income of the assessee. 37. Aggrieved by the action of AO, the assessee

Kasiredday Ranadheer Reddy, Bengaluru vs. ACIT, Central Circle-2(1), Bangalore

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

ITA 886/BANG/2025[2016-17]Status: DisposedITAT Bangalore02 Feb 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

nature of interest earned from money lending activities. The AO made an addition u/s 69 of the Act on account of unexplained money to the tune of Rs. 1,12,00,000 (Rs. 1 Crore principal and Rs. 12 Lakhs interest thereon) based on page 102 of A/ST/KKR/01. 5. Aggrieved ... payment of Rs. 5.5 crores in pursuance to the sale agreement, sources of which were not explained. Hence, the AO treated the same as unexplained money under section 69 of the Act and added to the total income of the assessee. 37. Aggrieved by the action of AO, the assessee