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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

Harish Sharma Prop., Ludhiana vs. The Income Tax Officer Ward 1(5), Ludhiana

In the result, we find that there is no justifiable basis to invoke the deeming fiction to hold the bank deposits as unexplained

ITA 670/CHANDI/2023[2012-2013]Status: DisposedITAT Chandigarh09 Sept 2024AY 2012-2013

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 147Section 148Section 69Section 69A

ground of appeal, the Ld. CIT(A) has erred in confirming the addition on merits to the tune of Rs. 28,31,000/-as unexplained money and not taking into consideration the facts that in the case of Sidhi Vinayak International, where the CIT(A) has deleted the addition

Harish Sharma Proprietor, Ludhiana vs. Income Tax Officer Ward 1(5), Ludhiana

In the result, we find that there is no justifiable basis to invoke the deeming fiction to hold the bank deposits as unexplained

ITA 669/CHANDI/2023[2011-2012]Status: DisposedITAT Chandigarh09 Sept 2024AY 2011-2012

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 147Section 148Section 69Section 69A

ground of appeal, the Ld. CIT(A) has erred in confirming the addition on merits to the tune of Rs. 28,31,000/-as unexplained money and not taking into consideration the facts that in the case of Sidhi Vinayak International, where the CIT(A) has deleted the addition

Kambli Prakash Dattu, Pune vs. NFAC, Delhi

Appeals of the assessee are PARTLY ALLOWED FOR STATISTICAL PURPOSES

ITA 1409/PUN/2024[2014-2015]Status: DisposedITAT Pune09 Sept 2024AY 2014-2015

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamore

For Appellant: None for the AssesseeFor Respondent: Mr BS Rajpurohit [‘Ld. DR’]
Section 147Section 250Section 250(6)Section 69A

failure on the part of the assessee to explain nature & source of deposits, the entire amounts of cash deposits were added as unexplained money u/s 69A and accordingly assessments for AY 2013-14 & 2014-15 were framed u/s 147 r.w.s. 144B of the Act. ITAT-Pune Page

Kambli Prakash Dattu, Pune vs. NFAC Delhi, Delhi

Appeals of the assessee are PARTLY ALLOWED FOR STATISTICAL PURPOSES

ITA 1408/PUN/2024[2013-2014]Status: DisposedITAT Pune09 Sept 2024AY 2013-2014

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamore

For Appellant: None for the AssesseeFor Respondent: Mr BS Rajpurohit [‘Ld. DR’]
Section 147Section 250Section 250(6)Section 69A

failure on the part of the assessee to explain nature & source of deposits, the entire amounts of cash deposits were added as unexplained money u/s 69A and accordingly assessments for AY 2013-14 & 2014-15 were framed u/s 147 r.w.s. 144B of the Act. ITAT-Pune Page

Om Prakash Agrawal HUF, Jaipur vs. ITO Ward 5(1), Jaiupr, Jaipur

ITA 967/JPR/2024[2012-13]Status: DisposedITAT Jaipur09 Sept 2024AY 2012-13
For Appellant: Sh. Sarwan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 147Section 148Section 234A

escaped assessment for any assessment year, here the assessee has not escaped any income because the assessee has never deposited the undisclosed or unexplained money in the bank account. Which shows that there was no escapement of income by the assessee, as the assessee is having business and trading

Turab Ali Bohra, Bhilwara vs. ACIT Central Circle, Ajmer

ITA 704/JPR/2023[2019-20]Status: DisposedITAT Jaipur09 Sept 2024AY 2019-20
For Appellant: Sh. Mahendra Gargieya (V.C)For Respondent: Sh. Anoop Singh, Add. CIT
Section 131Section 132ASection 133ASection 142(1)Section 143(2)Section 143(3)Section 144BSection 234ASection 69A

facts in confirming the additions made on account of the cash found from the possession of employee Shri Shyam Sundar Rathore as unexplained money u/s 69A of the Act. The addition so made and confirmed being completely contrary to the provisions of law and facts deserves to be deleted ... amount of Rs.22,49,500/- found from the possession of Shri Shyam Singh Rathore and belongs to Shri Turab Ali Bohra was considered as unexplained money of Shri Turab Ali Bohra for which he has not been able to satisfactorily prove the sources thereof. Accordingly, an addition of Rs.22

Ebro India Pvt.Ltd., Delhi vs. ACIT Circle-7(1), Delhi

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

done by the assessing officer nor has any tangible material been brought on record to support the allegation that the capital received from unexplained money. It has been held in the following decisions that where the initial onus to prove identity, creditworthiness and genuineness of the transaction has been discharged

Pallavi Devang Trivedi, Godhra vs. Nationa Faceless Assessment Centre, Delhi (Jurisdiction AO : the ITO, Ward-1), Godhra

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

ITA 843/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad06 Sept 2024AY 2014-15

Bench: Ms. Suchitra Kambleassessment Year: 2014-15

Section 143(1)Section 144Section 147Section 148Section 56(2)(vii)Section 69A

Section 69A Assessment Year: 2014-15 Page 2 of 3 of the Act cannot be invoked by treating the gift received from relative as unexplained money.” 3. The assessee is an individual and filed return of income on 27.03.2015 declaring income of Rs.2,13,800/-. The return was processed under

Shree Radha Madhav Gau Seva Charitable Turst, Bhavnagar vs. Income Tax Officer (Exemption Ward), Bhavnagar

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

ITA 606/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad06 Sept 2024AY 2017-18

Bench: Ms. Suchitra Kambleassessment Year: 2017-18

Section 115BSection 131Section 142(1)Section 144Section 144ASection 164Section 69A

Income Tax (Appeals), NFAC has erred in confirming the action of Assessing Officer in making addition of Rs.28,29,451/- on account of unexplained money u/s.69A of the I.T Act, 1961. Assessment Year: 2017-18 Page 2 of 4 4. On the facts and circumstances of the case as well ... NFAC has erred in confirming the action of Assessing Officer in invoking provisions of Section 115BBE of the Act and in thereby taxiing entire unexplained money at 60% and levying surcharge at 25% which is not applicable on above addition. 5. On the facts and circumstances of the case

Vishnu Kumar, Bharatpur vs. ACIT Or JCIT Or DCIT Or Asst. CIT Or ITO, National Faceless Assessment Centre, Bharatpur

ITA 85/JPR/2024[2015-16]Status: DisposedITAT Jaipur06 Sept 2024AY 2015-16

Bench: This Appellate Tribunal, Feeling Aggrieved By The Order Dated 08.12.2023 Passed, U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “ The Act”), By Learned Cit(A), Nfac, Delhi, Whereby His Appeal Relating To Assessment Year 2015-16 Has Been Dismissed. 2. The Assessee Was Before Learned Cit(A), Having Felt Dissatisfied With The Assessment Order Dated 29.03.2022 Passed By The Assessing

For Appellant: Shri Mukesh Soni, AdvFor Respondent: Shri Arvind Kumar, (CIT)
Section 133(6)Section 148Section 151Section 250Section 68

making an addition of Rs. 3,79,16,890/-. The only addition was made u/s 68 of the Act due to unexplained money. 3. Hence, this appeal against the order of dismissal of the appeal filed by the assessee. 4. Arguments heard. File perused. Return held to be invalid ... Raitani v. Commissioner of Income-tax, (1997) 223 ITR 544 (Gauhati). 28. On the other hand, while referring to the addition made as regard unexplained money to the tune of Rs. 3,79,16,890/- by the Assessing Officer, Ld. DR has submitted that the assessee failed to explain

Ambani Builders Private Ltd., Vadodara vs. The Asstt. Commissioner of Income Tax, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 304/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad05 Sept 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 37(1)Section 68Section 69A

since there was no proof to substantiate the contention, the AO held that the cash deposit to the tune of Rs.63,70,000/- are unexplained money u/s 69A of the Act. 5.4 Revenue recognition out of unexplained Closing Stock of finished goods: The AO noticed that during the year

Kanta Devi Jain, Jaipur vs. DCIT, Central-Circle 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 860/JPR/2024[2014-2015]Status: DisposedITAT Jaipur05 Sept 2024AY 2014-2015

Bench: The Hearing Of The Appeal.”

For Appellant: Sh. Tanuj Agarwal, AdvFor Respondent: Sh. Ajay Malik, CIT
Section 132(1)Section 139Section 143(3)Section 153A

that the assessee has paid of Rs. 54,00,000/- in cash out of his income from other undisclosed sources treating the same as unexplained money under provision of 69A of the Act. Undisputedly, the document was found and seized from the possession of the assessee but only ... that the assessee has paid of Rs. 54,00,000/- in cash out of his income from other undisclosed sources treating the same as unexplained money under provision of 69A of the Act. Undisputedly, the document was found and seized from the possession of the assessee but only

Padmavati Agrico (India) Pvt Ltd, Ajmer vs. ACIT Circle - 1, Ajmer

In the result, the appeal of the assessee is allowed

ITA 702/JPR/2023[2010-11]Status: DisposedITAT Jaipur05 Sept 2024AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal (CA)For Respondent: Sh. Anoop Singh (Addl. CIT)
Section 143Section 147

information in the form of statement of Shri Praveen Kumar Jain the Ld. AO has reached the conclusion that the share application money was unexplained money of the assessee whereas it is evident that statement has been retracted. Further Ld. AO has not doubted the identity of the parties

Manish Kumar Dubey, New Delhi vs. ITO, Ward-72(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2484/DEL/2023[2017-18]Status: DisposedITAT Delhi05 Sept 2024AY 2017-18

Bench: Shri Kul Bharat[Assessment Year : 2017-18] Manish Kumar Dubey, Vs Ito, E-4, 2Nd Floor, Gali No.3, Ward -72(1), East Chander Nagar, New Delhi. New Delhi-110051. Pan-Aotpd0936K Appellant Respondent Appellant By Shri Ravi Pratap Mall, Adv. Respondent By Shri Sanjay Kumar, Sr.Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 05.09.2024

Section 143(3)Section 69A

erred both in law as well as on facts upholding the addition of Rs. 7,74,000/- made by the Assessing Officer as unexplained money u/s 69A of the Income Tax Act, 1961. 2. That the learned NFAC grossly erred in failing to appreciate that source of cash deposit made

Leela Surukanti, Mahabubaad vs. ITO., Ward-1, Warangal

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

ITA 773/HYD/2024[2017-18]Status: HeardITAT Hyderabad04 Sept 2024AY 2017-18

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No. 773/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Smt. Leela Surukanti Vs. Income Tax Officer Mahabubad Ward-1 Pan:Awnps1700N Warangal (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G Venkat Nagaraju, Ca राज" व "ारा/Revenue By:: Shri S.P.G. Mudaliar, Dr सुनवाई की तारीख/Date Of Hearing: 04/09/2024 घोषणा की तारीख/Pronouncement: 04/09/2024 आदेश/Order

For Appellant: Shri G Venkat Nagaraju, CAFor Respondent: : Shri S.P.G. Mudaliar, DR
Section 143(2)Section 143(3)Section 44ASection 69A

deposits of Rs.1,57,58,452/- and addition of Page 2 of 5 ITA No 773 of 2024 Leela Surukanti Rs.17,34,500/- as unexplained money u/s 69A of the I.T. Act, 1961. 4. Aggrieved by the order of the learned CIT (A), the assessee is in appeal before ... business receipts of the assessee and estimated 8% profit on said cash deposits, is erred in making addition of Rs.17,34,500/- as unexplained money u/s 69A of the I.T. Act, 1961. Thus, I set aside the order passed by the learned CIT (A) and direct the Assessing Officer

Bushetty Nagaraju, Banaganapalli vs. Income Tax Officer, Ward-1, Nandyal

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

ITA 772/HYD/2024[2017-18]Status: HeardITAT Hyderabad04 Sept 2024AY 2017-18

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No. 772/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Busheety Nagaraju Vs. Income Tax Officer Banaganapally, Kurnool Ward – 1 Pan:Amrpn2666G Nandyal (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G.Subramanyam, Ca राज" व "ारा/Revenue By:: Shri S.P.G. Mudaliar, Dr सुनवाई की तारीख/Date Of Hearing: 04/09/2024 घोषणा की तारीख/Pronouncement: 04/09/2024 आदेश/Order

For Appellant: Shri G.Subramanyam, CAFor Respondent: : Shri S.P.G. Mudaliar, DR
Section 133(6)Section 143(1)Section 143(2)Section 69A

cash deposits into Andhra Bank amounting to Rs.28,19,000/- during the demonetization period. Thus, the Assessing Officer treated the said amount as unexplained money u/s 69A of the I.T. Act, 1961. 4. Being aggrieved, the assessee preferred an appeal before the learned CIT (A). The learned

Sanjay Upadhayay, Ratlam vs. ITO-1, Ratlam

In the result, the appeal of the appellant is dismissed

ITA 68/IND/2024[2017-18]Status: HeardITAT Indore04 Sept 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisanjay Upadhayay Ito-1 1/9/2004 Mig, Indra Nagar Ratlam Near Saint Stephens School Vs. Ratlam (Appellant / Assessee) (Respondent/ Revenue) Pan: Aalpu0989K Assessee By Mrs. Nish Lahoti, Ar Shri Ashish Porwal, Sr. Dr Revenue By Date Of Hearing 03.09.2024 Date Of Pronouncement 04.09.2024

Section 144Section 144wSection 69A

applicable law, Ld. CIT(A) erred in sustaining the addition of Rs. 32,47,000 made u/s 69A rws 115BBE as unexplained money. 3. On the facts and circumstances of the case and 19,48,20 applicable law. both Ld. AO and Ld. CIT(A) erred in making the addition ... made u/s 69A rws 115BBE as unexplained money without considering the submissions made by the assessee in response to Cash Transactions 2016 which are already on record with the Department 4. On the facts and circumstances of the case and applicable law, both Ld. AO and Ld. CIT(A) erred

Alagu Process, Tirupur vs. ITO, Ward 2(1), Tiruppur

In the result the appeal of the assessee is partly allowed

ITA 695/CHNY/2024[2017-18]Status: DisposedITAT Chennai04 Sept 2024AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.695/Chny/2024 िनधा"रण वष" /Assessment Year: 2017-18 Alagu Process, The Income Tax Officer, S.F No.414, Vs. Ward-2(1), Palavanjipalayam Ring Road, Tiruppur. Veerapandi Post, Tirupur – 641 605. [Pan: Aavfa 5147P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri S. Sridhar (Erode), Advocate ""थ" की ओर से /Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/Date Of Hearing : 26.06.2024 घोषणा की तारीख /Date Of : 04.09.2024 Pronouncement आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), (Nfac), Delhi [Hereinafter “Cit(A)”] In Din & Order No. Itba/Nfac/S/250/2023- 24/105992446(1), Dated 19.01.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2017-18 U/S.147 R.W.S

For Appellant: Shri S. Sridhar (Erode), AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 147Section 148Section 44ASection 68Section 69A

income of Rs.1,25,330/- as declared in the original return of income. The A.O has made addition of Rs. 13,85,000/- as unexplained money u/s. 69A of the Act by passing an order u/s.147 r.w.s 144B of the Act on 24.09.2021 by holding as under: “3. On verification ... passed /s 147 r.w.s :- 7 -: 144 B of the Income Tax Act, 1961 on 24/09/2021 by making an addition of Rs.13, 85, 000/- towards unexplained money U/s 69A of the Income Tax Act, 1961 for the AY 2017-18." 9.7.5 Therefore, irrespective of the fact that the AO inadvertently proceeded

Madhan HUF, Trichy vs. DCIT, Central Circle-1, Trichy

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

ITA 975/CHNY/2023[2015-16]Status: DisposedITAT Chennai04 Sept 2024AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 975/Chny/2023 िनधा"रणवष" / Assessment Year: 2015-16 Dcit/Acit, Madhan Huf, V. Central Circle 1, 284 Lawsons Road, Trichy. Cantonment, Trichy – 600 001. [Pan: Aaqhm-0598-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. N. Arjun Raj, Advocate ""यथ"क"ओरसे/Respondent By : Shri. N. Sanjay Gandhi, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 04.09.2024 आदेश /O R D E R

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. N. Sanjay Gandhi, JCIT
Section 131Section 133ASection 139Section 147Section 69A

this background, the A.O. has reopened the assessment, and completed the assessment by making an addition of Rs.4,63,75,948/- being the unexplained money utilized by the Appellant in making advance of Rs.4,60,00,000/- (Rs.3,50,00,000/- to Bagialakshmi andRs.1,10,00,000/- to T Mahesh ... Private Limited. Hence, the Assessing Officer treated the advance given to Smt. Bakialakshmi and to Shri T. Mahesh including the opening cash balance as unexplained money u/s 69A of the Act. In view of this, the grounds raised by the Appellant upon Merits are treated as dismissed as not sustainable

Sarangabani Kirubagaran, Chennai vs. DCIT, Circle-1(2), Chennai

The appeal stand allowed in terms of our above order

ITA 1238/CHNY/2023[2015-16]Status: DisposedITAT Chennai04 Sept 2024AY 2015-16

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Ms.T.V. Muthu Abirami (Advocate)-Ld.ARFor Respondent: Shri Nilay Baran Som (CIT) -Ld. DR
Section 132Section 133ASection 153CSection 271(1)Section 69Section 69ASection 69BSection 69C

under: - 7. However, before parting with, we may observe that there is a series of five provisions viz., Section 69-Unexplained investments, Section 69A- Unexplained money, etc., Section 69B-Amount of investments, etc., not fully disclosed in books of account 69C-Unexplained expenditure, etc. and 69D- Amount borrowed or repaid