“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

Neena Mahajan, Delhi vs. Income Tax Officer, Ward-28(1), Delhi

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

ITA 655/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Jul 2024AY 2015-16

Bench: Shri Shamim Yahya, A.Yr. : 2015-16 Neena Mahajan, Delhi Income Tax Officer, C/O Rajiv Goel & Associates, Vs. Ward 28(1), Delhi 179, Bank Road, Civic Centre, New Delhi – 2 Ambala Cantt-133001 Ambala, Haryana-133001 (Pan: Asspm0240Q) (Appellant) (Respondent)

For Appellant: Shri Dhruv Goel, CAFor Respondent: Shri Om Parkash, Sr. DR

Section 142(1)Section 148Section 45Section 69A

assessed income of Rs. 27,03,210/-. On perusal of assessment order it was observed that the addition was made on account of “unexplained money u/s. 69A of the I.T. Act, 1961” amounting to Rs. 12,08,000/- and “undisclosed income u/s. 45 of the I.T. Act, 1961 amounting

Jai Karan Singh, Mohali vs. Income Tax Officer, Ward-6(4), Mohali

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

ITA 638/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh12 Jul 2024AY 2017-18

Bench: JUSTICE (RETD.) C.V. BHADANG (President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

Section 115BSection 144Section 69A

accordingly, invoked the provision of Section 69A of the Act and held that the whole of the amount deposited in the bank account as unexplained money under section 69A of the Act and the same was brought to tax under section 115BBE @ 60% and the assessment order was passed under ... during the course of assessment proceedings, the AO completed the assessment u/s 144 bringing to tax the whole of the amount so deposited as unexplained money u/s 69A of the Act in the hands of the assessee which has since been confirmed by the ld CIT(A). During the course

Krutika Ashwin Sarvaiya, Ahmedabad vs. The ITO, Ward-5(3)(4), Ahmedabad

In the result, the appeal of the assessee in ITA

ITA 43/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2017-18

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: Shri S.N. Divatia, AdvocateFor Respondent: Smt. Trupti Patel, Sr. D.R

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

43/Ahd/2024 A.Y. 2017-18 Page No. 3 Krutika Ashwin Sarvaiya v. ITO during demonetization period to the extent of Rs.12,00,000/- was unexplained moneys u/s.69A and thereby confirming addition of Rs.20,00,000/-. 2.2 That in the facts and circumstances of the case as well

Prakash Shripal Chavan, Sangli vs. ITO, Ward-1, Sangli

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

ITA 580/PUN/2024[2017-18]Status: DisposedITAT Pune12 Jul 2024AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.580/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Prakash Shripal Chavan, Vs. Ito, Ward-1, Sangli. 1 Stand Road, Samdoli Sangli, Sangli- 416416. Pan : Ajlpc0555E Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Akhilesh Srivastava Date Of Hearing : 03.07.2024 Date Of Pronouncement : 12.07.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.02.2024 Passed By Ld Cit(A)/Nfac For The Assessment Year 2017-18. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. The Ld. Cit(A) Erred In Law & On Facts In Dismissing Appeal By Not Condoning The Delay When There Was Sufficient Cause For The Delay. 2. The Appellant Prays That The Delay May Kindly Be Condoned & The Appeal May Kindly Be Decided On Merits.” 3. The Facts, In Brief, Are That The Assessee Is An Individual & No Return Of Income Under The Provisions Of Section 139 Of The It Act

For Appellant: Smt. Deepa KhareFor Respondent: Shri Akhilesh Srivastava

Section 139Section 142(1)Section 147Section 148Section 69A

explained the source for the said cash deposits, the Assessing Officer made addition of Rs.1,33,43,600/- treating the same as unexplained money u/s 69A of the IT Act vide assessment order dated 31.03.2022 passed u/s 147 r.w.s. 144 of the IT Act. 4. Being aggrieved with the above

Palle Sathish Goud, Chintal Basti vs. Income Tax Officer, Ward 7(1), Kondapur

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

ITA 559/HYD/2023[2017-18]Status: HeardITAT Hyderabad12 Jul 2024AY 2017-18

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.559/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Palle Sathish Goud Vs. Income Tax Officer Chintal Basti Ward 7(1) Hyderabad Kondapur, Pan:Aijpp5303N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sashank Dundu, Advocate राज" व "ारा/Revenue By:: Smt.Sheetal Sariin, Dr सुनवाई की तारीख/Date Of Hearing: 10/07/2024 घोषणा की तारीख/Pronouncement: 12/07/2024 आदेश/Order

For Appellant: Shri Sashank Dundu, AdvocateFor Respondent: : Smt.Sheetal Sariin, DR

Section 115BSection 69A

cash in hand for such a long time. Therefore, rejected the argument of the assessee and made addition of Rs.15.00 lakhs u/s 69A as unexplained money and brought to tax u/s 115BBE of the I.T. Act, 1961. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before

Quality Broiler, Kancheepuram vs. ITO, Ncw-22(3), Tambaram

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

ITA 1124/CHNY/2024[2017-18]Status: DisposedITAT Chennai12 Jul 2024AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.1124/Chny/2024 िनधा8रण वष8 /Assessment Year: 2017-18 Quality Broilers, The Income Tax Officer, No.11, Block R1 Tower Centre, Vs. Non Corp Ward 22(3), Gandhi Nagar, Kattankulathur, Tambaram. Kancheepuram Dist, Tamil Nadu-603203. [Pan: Aaafq 4385N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथF की ओर से/ Appellant By : Shri S.P.Chidambaram, Advocate HiथF की ओर से /Respondent By : Shri G.Suresh, Jcit सुनवाई की तारीख/Date Of Hearing : 24.06.2024 घोषणा की तारीख /Date Of Pronouncement : 12.07.2024

For Appellant: Shri S.P.Chidambaram, AdvocateFor Respondent: Shri G.Suresh, JCIT

Section 142(1)Section 144Section 251(1)(a)

deposits of demonetized currency to the extent such profits are sufficient to account for the cash deposits and treat the excess if any as unexplained money deposited into the bank account. The addition for the remaining period after the cutoff date at the presumptive rate :- 3 -: needs to be calculated

Income Tax Officer, Income Tax Office vs. Appliances Forever, New Delhi

In the result the appeal of the Revenue stands dismissed

ITA 2842/DEL/2023[2017-18]Status: DisposedITAT Delhi12 Jul 2024AY 2017-18

Bench: Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 69A

case the Ld. CIT(A) erred in law in deleting the addition of Rs.65,53,340/-, made by A.O. on account of unexplained money u/s 69A of the IT Act. 2. On the facts and circumstances of the case the Ld. CIT(A) erred in allowing the appeal ... satisfactorily explained, then the value of such money is deemed to be the income of the assessee. This provision of the Act treats unexplained money as deemed income where the nature and source of cash deposits in the banks remains not explained or satisfactorily explained. No doubt, the assessee

Manchaiah Shivalingaiah, Bengaluru vs. Income Tax Officer Ward 1(2)(5), Bengaluru

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

ITA 944/BANG/2024[2017-18]Status: DisposedITAT Bangalore11 Jul 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeymanchaiah Shivalingaiah The Income Tax Officer No. 365/Ss, 1St Main, 2Nd Cross Ward - 1(2)(5) 3Rd Phase, Manjunath Nagar Vs. Bmtc Building, 80 Ft. Road Rajajinagar, Bengaluru 560010 Koramangala Pan – Bosps6014P Bengaluru 560095 (Appellant) (Respondent) Assessee By: Shri Likith Patel, M.K., Advocate Revenue By: Shri Ganesh R. Gahle, Standing Counsel Date Of Hearing: 19.05.2024 Date Of Pronouncement: 11.07.2024 O R D E R Per: Keshav Dubey, J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi / Cit(A) Vide Din & Order No. Itba/Nfac/S/250/2023-24/1062552904(1) Dated 13.03.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) For Assessment Year (Ay) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. On The Fact & Circumstances Of The Case, The Learned Cit(A) Erred In Upholding The Order Of The Assessing Officer, In The Manner In Which He Did. 2. On The Facts & Circumstances Of The Case, The Learned Cit(A) Erred In Providing Sufficient Opportunity To The Appellant To Put Forth The Submissions Of The Appellant.

For Appellant: Shri Likith Patel, M.K., AdvocateFor Respondent: Shri Ganesh R. Gahle, Standing Counsel

Section 143(2)Section 144Section 250Section 69

facts and circumstances of the case, the learned CIT(A) erred in upholding the addition of Rs. 13,99,500/- as unexplained money u/s 69(A) of the Act. 4. On the facts and circumstances of the case, the learned CIT(A) failed to appreciate that the notice of hearing ... entire cash deposited in the bank account during the demonetization period from 09.11.2016 to 30.12.2016 to the total income of the assessee as unexplained money and completed the assessment proceedings electronically under Section 144 of the Act under e-proceedings. Aggrieved, the assessee preferred appeal before

Gunvantbhai Narandas Patel, Gandhinagar vs. The Income Tax Officer, Ward-2, Gandhinagar

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

ITA 122/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad10 Jul 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

Section 148Section 250Section 54FSection 69A

following Grounds of Appeal: 1. The Leamed CIT (A) has erred in upholding the addition u/s 69A that of Rs. 53,00,000 as unexplained money though it is received against the possession of the property. 2. The Learned CIT (A) has erred in not appreciating the facts that ... that it relates to capital gain. Therefore, the amount is liable to be added under deeming provision of 69A. Section 69A reads as under Unexplained money, etc. I.T.A No. 122/Ahd/2024 A.Y. 2014-15 Page No 5 Gunvantbhai Narandas Patel vs. ITO 694. Where in any financial year the assessee

Mahendrabhai Shantilal Patel, Ahmedabad vs. DCIT, Central Circle-1(3), Ahmedabad

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

ITA 405/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad10 Jul 2024AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.405/Ahd/2019 "नधा"रण वष" /Assessment Year : 2010-11 Mahendrabhai Shantilal Patel The Dy.Cit D-41, Sahjanand Apartment बनाम/ Central Circle-1(3) Nr. Sterling Hospital Ahmedabad V/S. Gurukul Road,Memnagar Ahmedabad – 380 052 "थायी लेखा सं./Pan: Ayvpp 7593 G अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Vijay H. Patel, Ar (Written Submission) Revenue By : Shri Samir Tekriwal, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 04/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 10/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-12, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 20/12/2018, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) Under Section 143(3) R.W.S.147 Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 28/12/2017 Relevant To The Assessment Year (Ay) 2010-11. Mahendrabhai Shantilal Patel Vs. Dcit Asst. Year : 2010-11

For Appellant: Shri Vijay H. Patel, AR (Written submission)For Respondent: Shri Samir Tekriwal, CIT-DR

Section 132Section 132(4)Section 139Section 143(3)Section 148Section 234ASection 271(1)Section 68Section 69A

case, the Ld. CIT(A) has grossly erred in confirming the addition on account of summations of credit (cash & noncash) in bank account as Unexplained money u/s. 68 of the Act of Rs.81,09,90,322/-. The AO may be directed to delete such addition. 4) On the facts ... circumstances of the case, the Ld. CIT(A) has grossly erred in confirming the addition on account of Unexplained money u/s.69A of the Act of Rs.1,62,19,806/-. The A.O. may be directed to delete such addition. 5) On the facts and in the circumstances of the case

Manali Chimanrao Patil, Jalgaon vs. Income Tax Officer, Ward 2(3), Jalgaon

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

ITA 120/PUN/2024[2017-18]Status: DisposedITAT Pune10 Jul 2024AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.120/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Manali Chimanrao Patil, Vs. Ito, Ward-2(3), Mahalaxmi Auto Kajgaon Road, Jalgaon Parola Taluka, Parola, Jalgaon – 425 111 Maharashtra Pan : Aszpp2698G Appellant Respondent

For Appellant: Shri Sanket M. Joshi (through Virtual)For Respondent: Shri Ramnath P. Murkunde

Section 143(2)Section 144Section 69A

source of cash deposit, the AO vide order u/s.144 dated 26.12.2019 treated the expenses as Income from Business/Profession and the cash deposits made as unexplained money u/s.69A of the Act. 3. Being aggrieved by the above assessment order, an appeal was filed before the CIT(A) who vide impugned order

Shaharyar, Hyderabad vs. ITO Ward-14(1), Hyderabad

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

ITA 462/HYD/2024[2017-18]Status: HeardITAT Hyderabad10 Jul 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.462/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Shaharyar Vs. Income Tax Officer Hyderabad Ward 14(1) Pan:Fzyps6340M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Mohd.Afzal, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 10/07/2024 घोषणा की तारीख/Pronouncement: 10/07/2024 आदेश/Order

For Appellant: Shri Mohd.Afzal, AdvocateFor Respondent: : Shri Shakeer Ahmed, DR

Section 69A

Assessing Officer made addition of Rs.3,51,975/- and cash deposits from sale of property of Rs.10,43,727/- and treated the same as unexplained money u/s 69A r.w.s. 115BBE of the I.T. Act, 1961. 3. The learned AR for the assessee submitted that the learned CIT (A) has decided

The Mayavaram Financial Chit Corporation Limited, Nagapattinam vs. DCIT, Circle-2 (1), Trichy

ITA 80/CHNY/2024[2017-18]Status: DisposedITAT Chennai10 Jul 2024AY 2017-18

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 80/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 The Deputy Commissioner Of The Mayavaram Financial Chit V. Income Tax, Corporation Limited, Circle -2(1), 13-A1, Cutchery Road, Trichy. Mayiladuturai, Mayiladuturai Ho, Nagapattinam -609 001. [Pan: Aaact-2594-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri. P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 16.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 10.07.2024 आदेश /O R D E R

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. P. Sajit Kumar, JCIT

Section 115BSection 143(3)Section 68Section 69A

passed an order u/s. 143(3) of the Act on 23.12.2019 by holding Rs.13,37,000/- cash deposits made during demonetization period as unexplained money u/s. 69A of the Act. Aggrieved by the order of the Assessing Officer, the appellant preferred an appeal before the ld.CIT(A). 4. The ld.CIT ... after 9th November 2016 as prohibited by the law, cannot be entered into cash books. Therefore, the same has to be treated as unexplained money u/s 68 and brought to tax. In view of the foregoing facts the addition made

Nachimuthugownder Balasamy Karthikeyan, Erode vs. ITO, International Taxation Ward, Coimbatore

In the result, the appeal stand partly allowed

ITA 428/CHNY/2024[2018-19]Status: DisposedITAT Chennai10 Jul 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.428/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2018-19) Shri Nachimuthugownder Balasamy Ito बनाम/ Karthikeyan International Taxation Ward, 66, Kovalan 2Nd Street, Coimbatore. Vs. Teachers Colony, Erode-638 011. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aotpk-3606-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S.Sridhar (Advocate) Erode - Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S.Sridhar (Advocate) Erode - Ld.ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR

Section 144CSection 144C(5)Section 147Section 148Section 148ASection 151ASection 69

buyers with trade reference Id was also submitted. However, the assessee could not retrieve old trade receipts. Therefore, Ld. AO treated the same as unexplained money u/s 69A. There was another deposit of Rs.1.63 Lacs which were similar treated. The assessee maintained that these deposits were recorded in bank account

Income Tax Officer, Theni vs. Annadurai Mallika, Theni

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

ITA 954/CHNY/2023[2017-18]Status: DisposedITAT Chennai10 Jul 2024AY 2017-18

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 954/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Annadurai Mallika, Income Tax Officer, V. No. 22-10W, V O C Street, 74/74A, White House Street, Bodinayakanur, N R T Nagar, Theni, Theni – 625513. Tamil Nadu – 625531. [Pan: Bwkpm-9453-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Vikneswaran, Jcit ""यथ" क" ओर से/Respondent By : Shri. K. Mahesh Manickham, Ca सुनवाई क" तारीख/Date Of Hearing : 04.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 10.07.2024 आदेश /O R D E R

For Appellant: Shri. R. Vikneswaran, JCITFor Respondent: Shri. K. Mahesh Manickham, CA

Section 143(2)Section 44ASection 69A

Bank 111513500001122 93,55,000/- Axis Bank 914020049327942 12,56,000/- TOTAL 4,01,74,500/- 5. Therefore, added Rs.4,01,74,500/- as unexplained money u/s. 69A of the Act and concluded the assessment by making the following additions: Total income returned Rs. 6,36,020/- Total income ... appeal are 'Partly Allowed'. Aggrieved by the impugned action of the ld.CIT(A), deletion of the addition, which was made by the AO as unexplained money of Rs.4,01,74,500/- U/s.69A of the Act, the Revenue preferred an appeal before us. 7. The Ld.DR stated that, the Ld.CIT

Ravi Kumar, Salem vs. DCIT, Cricle 1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 1515/CHNY/2023[2017-18]Status: DisposedITAT Chennai10 Jul 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.1515/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 V. Shri Ravikumar, The Dcit, No.2/167-1, Green Avenue, Circle-1(1), Lrn Colony, Salem. Saradha College Road, Salem-636 007. [Pan: Aabpr 3092 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri G. Baskar, Advocate &For Respondent: Dr.D.Praveen, JCIT

Section 143(1)Section 143(2)

assessee filed replies to the AO. However, not satisfied with the replies/supporting documents, the AO made the following additions:- i) Rs.9,72,000/- as unexplained money and (ii) Rs.27,80,000/- as unexplained credits Ravikumar :: 3 :: 4. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A), who was pleased

Abhay Singh, Alwar vs. Income Tax Officer, Bhiwadi

In the result, the appeal of the assessee stands allowed with no orders as to costs

ITA 768/JPR/2024[2011-12]Status: DisposedITAT Jaipur10 Jul 2024AY 2011-12

For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 69A

after partial relief of Rs. 605773/- granted by the Ld CIT(A). In this regard, the provisions of section 69 A are quoted below :- Unexplained money, etc. 69A. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article ... INCOME TAX HIGH COURT OF CALCUTTA (2003) 183 CTR 0223, (2004) 265 ITR 0025, (2003) 130 TAXMAN 0553 - Section 69 A deals with unexplained moneys of which the assessee is found to be the owner. The material difference between section 68 and 69 A is that section 68 does

Harish Kumar Garg, Alwar vs. Income Tax Officer, Ward-1(1), Alwar

In the result, the appeal of the assessee stands allowed with no orders as to costs

ITA 767/JPR/2024[2013-14]Status: DisposedITAT Jaipur10 Jul 2024AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 148Section 44ASection 60ASection 69A

Further, SeC. 69 A are not applicable to the case of the assessee. The provisions of Sec. 69 A are quoted below :- Unexplained money, etc. 69A. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article ... TAXMAN 0553 8 ITA 767/JP/2024 HARISH KUMAR GARG VS ITO, WARD 1(1), ALWAR Section 69 A deals with unexplained moneys of which the assessee is found to be the owner. The material difference between section 68 and 69 A is that section 68 does not require that the amount

Satish Chandra Gupta, Jaipur vs. ITO Ward 2(4), Jaipur

In the result, the appeals of the assessee are allowed

ITA 509/JPR/2024[2011-12]Status: DisposedITAT Jaipur10 Jul 2024AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR

Section 143(3)Section 147Section 148Section 234ASection 69

cash of the assessee which has been deposited in bank account, then there is no question of making addition under the unexplained money u/s 69A of the IT Act 1961. Recently ITAT Jodhpur Tribunal under the same facts and circumstances in the case of Krishna Agarwal

Rajiben Raja Bera, Mumbai vs. Commissioner of Income Tax (Appeal)-NFAC, Delhi

The appeal of the assessee is partly allowed in above terms

ITA 1412/MUM/2024[2017-18]Status: DisposedITAT Mumbai10 Jul 2024AY 2017-18

Bench: Shri Satbeer Singh Godara (Jm) & Shri Girish Agrawal (Am)

Section 115BSection 143(3)Section 69A

sole substantive grievance which arises for our apt adjudication is that of correctness of lower authorities action making section 69A read with section 115BBE unexplained money addition of Rs. 25,00,000/- made in course of assessment dated 29.11.2019, as upheld in the lower appellate discussion. Both the representatives reiterated