“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

Rohit Darak, Indore vs. ACIT Central-2, Bhopal

ITA 103/IND/2025[2018-19]Status: DisposedITAT Indore30 Jan 2026AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 132Section 139(1)Section 142(1)Section 143(2)Section 144Section 153ASection 250Section 253

Through these grounds of appeal the appellant has challenged the various additions made on account of unexplained money u/s 69A of the IT Act, 1961 for the relevant AYs. 3.3.1 I have considered the facts and circumstances of the assessment order and the case and the grounds of appeal filed ... erred in law and on facts in making addition and Ld. CIT(A) has erred in confirming addition of Rs. 67,500 as Unexplained money U/s 69A of Income Tax Act, 1961 in the form of commission income alleged to be received for arranging accommodation entries. 2. That

Rohit Darak, Indore vs. ACIT Central-2, Bhopal

ITA 102/IND/2025[2017-18]Status: DisposedITAT Indore30 Jan 2026AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 132Section 139(1)Section 142(1)Section 143(2)Section 144Section 153ASection 250Section 253

Rohit Darak, Indore vs. ACIT Central-2, Bhopal

ITA 101/IND/2025[2016-17]Status: DisposedITAT Indore30 Jan 2026AY 2016-17

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 132Section 139(1)Section 142(1)Section 143(2)Section 144Section 153ASection 250Section 253

Rohit Darak, Indore vs. ACIT Central-2, Bhopal

ITA 100/IND/2025[2014-15]Status: DisposedITAT Indore30 Jan 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 132Section 139(1)Section 142(1)Section 143(2)Section 144Section 153ASection 250Section 253

Karunesh Kumar Shukla, Lucknow vs. Income Tax Officer-1(1), Lucknow

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

ITA 668/LKW/2025[2018-19]Status: DisposedITAT Lucknow30 Jan 2026AY 2018-19

For Appellant: Sh. Samrat Chandra, C.AFor Respondent: Sh. Koushlendra Tiwari, CIT DR

Section 144Section 148Section 69Section 69A

immovable properties, an addition of Rs. 85,00,000/- on account of unexplained investment in time deposits and Rs. 29,91,000/- as unexplained money under section 69A. 3. Aggrieved by the said assessment order, the assessee filed an appeal before the NFAC. However, the ld. CIT(A) records that

Bhimrav Mahtarji Sonwane, Tad Pimpalgaon vs. ITO Ward 1(5), Aurangabad

In the result, appeal of the assessee is allowed

ITA 3096/PUN/2025[2022-2023]Status: DisposedITAT Pune30 Jan 2026AY 2022-2023

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3096/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Bhimrav Mahtarji Sonwane, V Income Tax Officer, At Post Tad Pimpalgaon Ta S Ward-1(5), Aurangabad. Kannad Dist Aurangabad, Aurangabad – 431115. Pan:Cnzps9338D Appellant/ Assessee Respondent /Revenue Assessee By Shri Mukesh Chudiwal Revenue By Shri Ajitesh Kumar Meena – Addl.Cit Date Of Hearing 28/01/2026 Date Of Pronouncement 30/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23Dated 17.10.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Act, Dated 28.02.2024. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A). Nfac Erred In Dismissing The Appeal Ex-Parte Without Considering The Written Submissions, Documents, Books Of

Section 131Section 143(3)Section 144Section 144BSection 250Section 250(6)Section 69A

assessee from Sri. Ashish Rameshchand sahuji of Rs 11,46,800/- stands unexplained and not offered for taxation. Accordingly, it is treat it as unexplained money and added to the Total Income of the assessee u/s. 69A r.w.s. 115BBE of the Income Tax Act. Summary of additions made

Income Tax Officer, Ward-8(1), Hyderabad vs. Dagumati Swathi, Hyderabad

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

ITA 1638/HYD/2025[2013-14]Status: DisposedITAT Hyderabad30 Jan 2026AY 2013-14

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 13Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 151A

entire amount of cash deposits of Rs.1,34,43,924/- made in the bank account of the assessee held with Andhra Bank as her unexplained money and assessed her income at the same amount. 5. Aggrieved, the assessee assailed the assessment order before the CIT(A). The assessee

Satya Kour, Hyderabad vs. ITO., Ward-17(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1032/HYD/2025[2016-17]Status: DisposedITAT Hyderabad30 Jan 2026AY 2016-17

Bench: SHRI G. MANJUNATHA, HON'BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 147Section 148Section 148ASection 151ASection 4Section 69A

144B of the Act by passing an order dated 18.01.2024, determining income at Rs.88,91,872/- by making addition of Rs.58,48,422/- as unexplained money u/s 69A r.w.s. 115BBE of the Act and Rs.25,00,000/- as unexplained investment u/s 69 r.w.s.115BBE of the Act. 7. Aggrieved

Ramesh Babu Bejjala, Kothagudem vs. Income Tax Officer, Ward-1, Kothagudem

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

ITA 1010/HYD/2025[2015-16]Status: DisposedITAT Hyderabad30 Jan 2026AY 2015-16

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 149(1)(b)Section 348Section 44ASection 63A

returned by the assessee in his return of income filed under section 148 of the Act, held the entire amount as the assessee’s unexplained money under section 69A of the Act. Accordingly, the AO/NFAC vide his order passed under section 147 r.w.s 144B of the Act, dated 21/12/2023 assessed

Anthonette Joaquim Anthony, Mumbai vs. ITO Int Tax Ward 1(1)(1), Mumbai

ITA 6531/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Devendra JainFor Respondent: Shri Krishna Kumar, Sr. DR

Section 115BSection 144BSection 144C(13)Section 144C(5)Section 147Section 148Section 148ASection 151Section 151ASection 69

with the impugned directions of Hon'ble Dispute Resolution Panel u/s. 144C(5) dated 30.06.2025), has erred in adding as alleged unexplained investment or unexplained money u/s section 69/69A to the income of the Appellant. 5) In the facts and circumstances of the case and in law, the Ld. Assessing ... Resolution Panel u/s. 144C(5) dated 30.06.2025), has erred in invoking the provisions of section 115BBE on the alleged addition of unexplained investment or unexplained money of 2,10,500/- thereby taxing the said amount @ 60%.” 4. During the hearing, the learned Authorised Representative (“learned AR”), at the outset, submitted

Dhaval Dinesh Shah, Vasai, Thane vs. Ward 42(1)(2), Mumbai

Accordingly, Ground No.4 raised by the Assessee are allowed for statistical purposes

ITA 5575/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Asif KarmaliFor Respondent: Shri Annavaran Kosuri

Section 143(2)Section 143(3)Section 270ASection 69A

erred in law and on fact in confirming the additions made by the AO treating 50% of the cash deposit 69,68,066/- as unexplained money earned from undisclosed sources as per provision of section 69A of the Income Tax 1961 during the Assessment Year 2017-2018 demonetisation period (Total

Akshay Deepak Talim, Mumbai vs. Income Tax Officer Ward 4(1)(1), Mumbai

ITA 5130/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Suhas Kulkarnai, AdvFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(3)Section 147Section 148Section 148ASection 149Section 69A

case and in law, the Ld. DRP and the Ld. AO erred in treating the amount deposited in the lenders' accounts as unexplained money in the hands of the assessee, without having any supporting evidence and without conducting any enquiry into the genuineness of the said transactions ... hereby show cause as to why the total loan of Rs.12,35,000/- received from these three donors should not be treated as unexplained money and added to your total income. You were already given an opportunity to reply the already given an the above vide show cause notice dated

Nivrutti Pandurang Bhor, Mumbai vs. ITO 27(2)(1), Mumbai

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

ITA 3589/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Mr. Nivrutti Pandurang Bhor, Income Tax Officer - 27(2)(1), B/502, Shiv Prerna Chs. Lts, Tower No.6, Andheri Link Road, Vs. Vashi Railway Station Complex, Asalpha Village, Vashi Navi Mumbai– 400 703 Mumbai – 400 072 Pan:Aagpb5212K (Appellant) (Respondent) :

For Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR

Section 142(1)Section 143(3)Section 250Section 263Section 54

making addition of Rs.36,35,520/- towards the LTCG, Rs.35,993/- under the head “Income from other sources” and Rs.13,84,112/- as unexplained money u/s. 69A of the Act. 4. Aggrieved, the assessee was in appeal before the first appellate authority, who vide order dated 20.05.2025 upheld the addition

Hansraj, Rewari vs. ITO Ward 1(4), Gurgaon

In the result, appeal of the assessee is partly allowed

ITA 4978/DEL/2025[2014-15]Status: DisposedITAT Delhi30 Jan 2026AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh, Ita No:- 4978/Del/2025 (Assessment Year- 2014-15) Hansraj, Income Tax Officer, C-75, Ground Floor, Ward-1(4), M2K County, Dharuhera Vs Gurugram, Rewari, Haryana-123106. Haryana-122001. Pan- Aazph7436E Assessee Revenue

Section 139(1)Section 147Section 148

Account No.21013002735 was not verifiable. Accordingly, the Page 4 of 10 ITA No.- 4978/Del/2025 Hansraj amount of Rs.1,01,50,000/- was treated as unexplained money u/s.69A of the Act and added to the total income of the assessee and tax payable on this addition was computed

James Christopher, Zuarinagar vs. Income Tax Officer, Ward - 2(4), Panaji

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

ITA 455/PAN/2025[2017-18]Status: DisposedITAT Panaji29 Jan 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. No.455/Pan/2025 (A.Y. 2017-18) James Christopher, Vs Ito-Ward 2(4), H.No.11, Behind Kiran Niketan Pundalik Niwas, . Prim, Zuarinagar-403726, Rua-De-Qurem, Goa. Cortim,Panaji, Goa-403001, Pan,No.Abmpc9362N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Sri.Sandesh Padiyar.Ar Revenue By Shri.S.Gurukumar.Sr.Dr सुनवाई की तारीख/Date Of Hearing 22.01.2026 घोषणा की तारीख/Date Of Pronouncement 29.01.2026 Order Per Pavan Kumar Gadale ,Jm: The Assesse Has Filed The Appeal Against The Order Of The Addl/Jcit(A) Thiruvanantpuram Passed U/Sec143(3) & U/Sec 250 Of The Act. The Assesee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Addition U/Sec69A Of The Act Made By The Assessing Officer. 2. The Brief Facts Of The Case Are That, The Assessee Is A Lecturer In Mes College Zuari Nagar, Goa. The Assessee Has Filed The Return Of Income For A.Y.2017-18 On 4.08.2017 Disclosing A Total Income Of Rs.8,54,310/-. Subsequently The Case Was Selected For Limited Scrutiny

Section 69A

satisfied with the explanations and relied on the provisions of section 69A of the Act and judicial decisions and made addition of unexplained money u/sec69A of the Act of Rs.11,95,000/- and assessed the total income of Rs.20,49,310/- and passed the order u/sec

Binay Kumar, West Champaran vs. ITO, Ward- 1 (5), Bettiah

Appeal of the assessee is allowed for statically purpose

ITA 440/PAT/2025[2018-19]Status: DisposedITAT Patna29 Jan 2026AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.440/Pat/2025 Assessment Year: 2018-19 Binay Kumar.………………….………………. …………………....Appellant C/O Andrasan Bhagat, Ward No.08, Muniya Tola Chikarpur, Narkatia Ganj, West Champaran, Pin-845455.. [Pan: Enwpk4043J] Vs. Ito, Ward-1(5), Betiah……..…..……………..………………….…..... Respondent Appearances By: Shri Ravi Shankar, Adv., Appeared On Behalf Of The Appellant. Md. A H Chowdhury Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 28, 2026 Date Of Pronouncing The Order : January 29, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 18.07.2025 Passed By The Nfac, Delhi U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Had Made Total Cash Deposits Of 5,29,66,187 In His Bank Account Maintained With The State Bank Of India During The Relevant Assessment Year. The Assessing Officer Observed That The Assessee Did Not Disclose The Said Amount As Income & Failed To Pay Tax Thereon. Since The Assessee Could Not Satisfactorily Explain The Nature & Source Of The Deposits, The Assessing Officer Treated The Same As Unexplained Money Under Section

Section 115BSection 250

thereon. Since the assessee could not satisfactorily explain the nature and source of the deposits, the Assessing Officer treated the same as unexplained money under section I.T.A. No.440/Pat/2025 Binay Kumar 69A, read with section 115BBE of the Income-tax Act, 1961, and added it to the total income

Mohammad Kasif Raja, Milik Tola, Khoksa, Baisi vs. Income Tax Officer, Ward 3(1), Purnea

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

ITA 322/PAT/2025[2017-18]Status: DisposedITAT Patna29 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(2)Section 144Section 250Section 44ASection 69A

cash deposit of ₹91,000/- and accordingly, he added the same to the total income of the assessee u/s 69A of the Act as unexplained money and further ₹4,18,613/- was also added for misreporting of proper income and assessed the total income of the assessee

Harmandeep Kaur, Ludhiana vs. Income Tax Officer, Ward-6(1), Ludhiana

In the result, appeal of the assessee is allowed

ITA 1385/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh29 Jan 2026AY 2023-24

Bench: Shri Rajpal Yadavआयकर अपील सं./ Ita No. 1385/Chd/2025 "नधा"रण वष" / Assessment Year: 2023-24 Smt. Harmandeep Kaur, The Ito, House No.1182, Basant Avenue Extn., Vs Ward-6(1), Phullanwal, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Blypk1410Q अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Ca Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 22.01.2026 Date Of Pronouncement : 29.01.2026

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 115BSection 143(2)Section 69A

single issue, namely, whether addition of Rs.27,50,000/- made by the AO by treating the A.Y.2023-24 2 sale proceeds of immovable properties as unexplained money deserve to be confirmed in her hand or not. 3. The brief facts of the case are that assessee has filed her return

Om Parkash Saini, Ganda Pura Mustaffabad vs. Ward 5, Yamuna Nagar

In the result, appeal of the assessee is allowed

ITA 1261/CHANDI/2025[2017-2018]Status: DisposedITAT Chandigarh29 Jan 2026AY 2017-2018

Bench: Shri Rajpal Yadavआयकर अपील सं./ Ita No. 1261/Chd/2025 "नधा"रण वष" / Assessment Year: 2017-18 Om Parkash Saini, The Ito, H.No. 2, Village-Gandapura, Vs Ward-5, Mustaffabad, Distt. Yamuna Nagar, Jagadhri. Yamunanagar. "थायी लेखा सं./Pan No: Adips0044D अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Yad Ram Saini, Advocate & Shri Neeraj Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 22.01.2026 Date Of Pronouncement : 29.01.2026

For Appellant: Shri Yad Ram Saini, Advocate and Shri Neeraj Jain, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR

Section 115BSection 271ASection 69A

extent of Rs. 7,26,090/- (11,30,000 - 4,03,910) which are appearing in the bank accounts of assessee, is considered as unexplained money u/s 69A of the Income Tax Act, 1961. Therefore, Rs.7,26,090/- is held as income of the assessee from undisclosed sources which

Vankar Dayabhai, Vadodara vs. The ITO, Ward-3(1)(4), Vadodara

ITA 2261/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kamble

For Appellant: Shri Akshay M. Modi, A.RFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R

Section 144BSection 147Section 148Section 151ASection 270ASection 271ASection 272A(1)(d)Section 69

case as well as in law, both the lower authorities erred in making addition treating cash of Rs. 18,70,300/- being unexplained money is bad-in-law, illegal and deserves to be deleted. 5 Your appellant further reserves his rights to add, alter, amend or modify