“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

Manoj Dayachand Jain HUF, Mumbai vs. ITO- 19(2)(3), Mumbai

Appeal is allowed for statistical purposes in above terms

ITA 4176/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Jul 2024AY 2017-18

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

Section 144Section 154Section 250(6)Section 69A

outset during the course of hearing that the NAFC, the lower appellate ex-parte discussion; affirming the Assessing Office’s action making section 69A unexplained money addition of Rs. 87,49,400/-, has not effectively complied with the rigor of section 250(6) requiring framing of points of determination followed

Baba Shivaji Khawale, Pune vs. Income Tax Officer Ward 8(3), Pune

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

ITA 843/PUN/2024[2016-17]Status: DisposedITAT Pune09 Jul 2024AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.830 & 843/Pun/2024 िनधा"रण वष" /Assessment Year : 2016-17 Baba Shivaji Khawale, Vs. Ito, Ward-8(3), Sr.No.1264, Pune Near Nagaraj Body Builder, Chikhali, Pune – 411 062 Maharashtra Pan : Bqapk3725R Appellant Respondent

For Appellant: Shri B.B. ManeFor Respondent: Shri Ramnath P. Murkunde

Section 139(1)Section 142(1)Section 144Section 148Section 271(1)(b)

circumstances, the AO was constrained to complete the assessment u/s.144 r.w.s147 of the Act after making addition of Rs.40,97,570/- as unexplained money. Thereafter, the AO levied penalty of Rs.10,000/- u/s.271(1)(b) of the Act. 4. Being aggrieved by the above penalty order, an appeal was filed

Baba Shivaji Khawale, Pune vs. Income Tax Officer Ward 8(3), Pune

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

ITA 830/PUN/2024[2016-17]Status: DisposedITAT Pune09 Jul 2024AY 2016-17

For Appellant: Shri B.B. ManeFor Respondent: Shri Ramnath P. Murkunde

Section 139(1)Section 142(1)Section 144Section 148Section 271(1)(b)

Sunil Kumar Mishra, Howrah vs. ITO, Ward-40(1), Kolkata

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

ITA 277/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Jul 2024AY 2017-18

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. No.277/Kol/2024 Assessment Year: 2017-18 Sunil Kumar Mishra ………. Appellant (Pan: Ahppm0825R) Vs. Income Tax Officer, Ward-40(1), Kolkata. ………… Respondent Appearances By: Shri Gopal Ram Sharma, Ar Appeared For Appellant. Shri P. P. Barman, Addl. Cit, Sr. Dr Appeared For Respondent. Date Of Concluding The Hearing : 04.06.2024 Date Of Pronouncing The Order : 09.07.2024 Order Per Manish Borad: This Appeal Filed By The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2017-18 Is Directed Against The Order Passed U/S 250 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Commissioner Of Income-Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 21.07.2023 Arising Out Of The Assessment Order U/S 144 Of The Act By Ito, Ward-40(1), Kolkata Dated 24.12.2019. 2. Registry Has Informed That This Appeal Of Assessee Is Time Barred By 96 Days. Application For Condonation Of Delay Has Been Filed By Assessee. Perusal Of The Same & Also Considering The Ratio Of I.T.A. No. 277/Kol/2024 Sunil Kumar Mishra, Ay : 2017-18

Section 115BSection 144Section 246ASection 250Section 264Section 271ASection 69A

Madras). 6. For that the addition of Rs.1,25,90,000/- u/s. 69A of the Act treating the total deposit during the year as unexplained money is illegal & void. 7. For that the Ld. CIT (A) erred in not considering submission of the assessee who prayed for deleting additions made

Tarun Kumar, Panipat vs. ITO, Ward-47(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 4012/DEL/2019[2009-10]Status: DisposedITAT Delhi09 Jul 2024AY 2009-10

Bench: Shri Saktijit Dey, Hon’Ble & Shri M. Balaganeshtarun Kumar, Vs. Ito, C/O. Anil Kumar, Advocate, Ward-47(1), 1727, Sector-12, Huda, Panipat New Delhi (Appellant) (Respondent) Pan: Aubpk7824P

For Appellant: NoneFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR

Section 142(1)Section 147Section 148Section 271(1)(C)Section 68

assessment proceedings, cash deposits made in the bank accounts of HDFC Bank, Sirsa and ING Vysya , Ludhiana were sought to be added as undisclosed / unexplained money in the hands of the assessee to the tune of Rs 3,06,62,200/-. The ld. AO recorded statement from the assessee during

Mohan Pandurangji Kharalkar, Nagpur vs. Income Tax Officer, Ward 4(5), Nagpur

In the result, the appeal of the assessee is allowed

ITA 416/NAG/2023[2017-18]Status: DisposedITAT Nagpur08 Jul 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay Agrawal, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr.Dr

Section 143(3)Section 250Section 44ASection 69A

deposit on 11/11/2016 of Rs.2,10,000/- (2,00,000+10,000) is allowed and remaining amount of Rs.56,73,000/- is treated as unexplained money in the hands of the assessee and added to his total income. Separate proceedings u/s 271AAC are initiated for addition made u/s 69A.” Mohan ... gainful to refer Section 69A of the IT Act, 1961, at this juncture as follows, to effectively analyse the entire gamut of the issue: "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

ACIT, Central Circle-2(2), Hyderabad vs. Syed Irfanuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 442/HYD/2022[2018-9]Status: DisposedITAT Hyderabad08 Jul 2024

Bench: Shri Laliet Kumar & Shri Manjunatha, G.S.No Appeal In Ita No Revenue Assessee A.Y 1 432/Hyd/2022 Acit, Syed 2018- Central Zeeshanuddin 19 Circle 2(2) Hyderabad Hyderabad Pan:Bqgps0128A 2 436/Hyd/2022 & -Do- Syed Imranuddin 2017- 437/Hyd/2022 Hyderabad 18 3 Pan:Aajpi6494F 4 442/Hyd/2022 -Do- Syed Irfanuddin 2018- Hyderabad 19 Pan:Aappi4693A िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132(4)

automatically fall under the sections 68 to 69D unless specifically resorted to. Sections 68 to 69D deem certain unexplained cash credits, unexplained investment, unexplained money, bullion or jewellery or unexplained expenditure as income. One has to specifically state under which section the additional income falls and the reasons for doing ... cover any discrepancy is concerned, the A0 has not pointed out any unexplained credit in the books of account, any unexplained investment, any unexplained money, bullion or jewellery, any unexplained expenditure or any amount of loan repaid in the assessment order in this respect. Therefore, the provisions of Section

ACIT, Central Circle-2(2), Hyderabad vs. Syed Imranuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 437/HYD/2022[2018-19]Status: DisposedITAT Hyderabad08 Jul 2024AY 2018-19

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132(4)

ACIT, Central Circle-2(2), Hyderabad vs. Syed Imranuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 436/HYD/2022[2017-18]Status: DisposedITAT Hyderabad08 Jul 2024AY 2017-18

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132(4)

ACIT Central Circle-2(2), Hyderabad vs. Syed Zeeshanuddin, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 432/HYD/2022[2018-19]Status: DisposedITAT Hyderabad08 Jul 2024AY 2018-19

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132(4)

Tapan Kumar Barman, Sodepur vs. ITO, Ward-50(5), Kolkata

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

ITA 85/KOL/2024[2017-18]Status: DisposedITAT Kolkata08 Jul 2024AY 2017-18

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 85/Kol/2024 Assessment Year: 2017-18 Tapan Kumar Barman Income Tax Officer, Ward-50(5), D-3/303, Peerless Nagar Vs Kolkata Sodepur, P.O. Panihati 24 Parganas (N) West Bengal - 700114 [Pan : Afwpb7516H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Siddharth Agarwal, Advocate Revenue By : Shri G. Ajay Robin Singh, Jcit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 13/06/2024 घोषणा क" तारीख /Date Of Pronouncement: 08/07/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Orderof The National Faceless Appeal Centre, (Hereinafter The “Ld. Cit(A)”) Dt.11/12/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For Assessment Year 2017-18. 2. Though The Assessee Has Raised As Many As Six Grounds Of Appeal But The Sole Grievance Of The Assessee Is That Since The Impugned Order Is Ex-Parte & Even The Assessee Could Not Appear Before The Ld. Assessing Officer For Bonafidereasons & No Details Could Be Filed Before The Lower Authorities & Thus Made Prayer To Restore The Matter Back To The File Of The Ld. Assessing Officer For De Novo Assessment. 3. We Have Heard Rival Contentions & Perused The Material Placed Before Us. We Note That The Assessee Is An Individual & 2

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri G. Ajay Robin Singh, JCIT, Sr. D/R

Section 143(2)Section 250Section 69A

Rs.53,11,500/- added in the hands of the assessee in the hands of the assessee u/s 69A of the Act as unexplained money of the Act as unexplained money and assessed income at and assessed income at Rs.64,21,210/-. Dissatisfied with the order of the ld. Assessing . Dissatisfied

Mani Dinesh, Namakkal vs. ITO Ward 2, Tiruchengode

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

ITA 814/CHNY/2024[2011-12]Status: DisposedITAT Chennai08 Jul 2024AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 814/Chny/2024 िनधा"रणवष" / Assessment Year: 2011-12 Income Tax Officer, Mani Dinesh V. Ward -2, No.3/740, Ethirmedu Tiruchengode. Thattankuttai, Komarapalayam, Namakkal – 638 183. [Pan: Awspd-5423-G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S. Sridhar, Advocate (Erode) (Virtual) ""यथ"क"ओरसे/Respondent By: Shri. G. Suresh, Jcit सुनवाईकीतारीख/Date Of Hearing : 08.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 08.07.2024 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Shri. S. Sridhar, Advocate (Erode) (virtual)For Respondent: Shri. G. Suresh, JCIT

Section 143(2)Section 143(3)Section 148Section 44ASection 69Section 69A

being heard, and made an addition of cash deposits made to the bank account of Rs.18,00,000/- U/s.69A of the Act, as unexplained money. Aggrieved by the order of the AO, assessee preferred an appeal before the ld.CIT(A). 3. The ld.CIT(A) had issued notices granting opportunities

M/S. Emirates Hindustan Builders and Developers, Kerala vs. Assistant Commissioner of Income-Tax, Central Circle-2, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 415/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Guru Kumar S., D.R

Section 132(4)Section 143(3)Section 148Section 68

assumptions and presumptions. 7. The learned Assessing Officer is not justified in law in additions made in the hands of the appellant as unexplained money, mainly based on the statement made at the time of survey without any corroborative evidence or material. 8. The learned assessing officer has grossly ignored

Mkh Infrastructure, Kerala vs. Deputy Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 174/BANG/2024[2017-18]Status: DisposedITAT Bangalore08 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Guru Kumar S., D.R

Section 132(4)Section 143(3)Section 148Section 68

Kailash Gahlot, New Delhi vs. DCIT, Central Circle-4, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 3505/DEL/2023[2018-19]Status: DisposedITAT Delhi08 Jul 2024AY 2018-19

Bench: Shri C. N. Prasad & Shri M. Balaganeshkailash Gahlot, Vs. Dcit, C-6/6172, Vasant Kunj, Central Circle-4, New Delhi Delhi (Appellant) (Respondent) Pan:Aajpg2849N

For Appellant: Shri Vinod Bindal, CAFor Respondent: Mr. Waseem Arshad, CIT DR

Section 115BSection 132Section 153ASection 292CSection 69A

decided in this appeal is as to whether the ld CIT(A) was justified in upholding the addition made on account of unexplained money in the sum of ₹5 lakhs u/s 69A r.w.s 115BBE of the Act in the facts and circumstances of the instant case. Kailash Gahlot ... that the assessee had not substantiated the evidence covered in the form of Whatsapp Chat and accordingly made an addition of ₹5 lakhs as unexplained money in the hands of the assessee u/s 69A read with Section 115BBE of the Act and completed the assessment. This action

Income Tax Officer, Ward1, Ahmednagar vs. Atul Ashok Parakh, Ahmednagar

The appeal are allowed

ITA 304/PUN/2024[2017-18]Status: DisposedITAT Pune05 Jul 2024AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: Shri Prasad S BhandariFor Respondent: Shri Pawan Bharati

Section 132Section 132(4)Section 133(6)Section 147Section 69

further surprising to note that the AO has treated and added this sum under the provisions of section 69 of the Act as unexplained money whereas the said section pertains to unexplained investment. The section reads as under:- "Where in the financial year immediately preceding the assessment year the assessee

Muthusamy Senthilkumar, Namakkal vs. ITO, Ward-1, Namakkal

In the result, appeal filed by the assessee is allowed

ITA 673/CHNY/2024[2017-18]Status: DisposedITAT Chennai05 Jul 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.673/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 V. Shri Muthusamy Senthilkumar, The Income Tax Officer, 142G2 Opp. V.S.Mani Petrol Bunk, Ward-1, Salem Road, Namakkal. Namakkal-637 001. [Pan: Baeps 3189 M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri T.S.Lakshmi –For Respondent: Shri P. Sajit Kumar, JCIT

Section 69A

assessee is against action of the Ld.CIT(A) confirming the action of the AO making an addition of Rs.23,08,000/- as unexplained money u/s.69A r.w.s.115BBE of the Income Tax Act, 1961 (hereinafter in short “the Act"), despite assessee had brought to their notice that as on 08.11.2016 (i.e. before ... Rs.23,08,000/-, according to the AO, cannot be considered as reasonable, since it was deposited beyond reasonable time and treated the same as unexplained money u/s.69A r.w.s.115BBE of the Act. 5. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A), who was pleased to confirm the same

Vrv Lungi Company, Chennai vs. ACIT, Central Circle 3(2), Chennai

In the result, appeal filed by the assessee is allowed

ITA 444/CHNY/2023[2019-2020]Status: DisposedITAT Chennai05 Jul 2024AY 2019-2020

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.444/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. M/S.Vrv Lungi Co., The Acit, No.3, Indrani Street, Central Circle-3(2), Ayyavoo Naidu Colony, Chennai. Chennai-600 029. [Pan: Aaefv 8392 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N.Arjun Raj, AdvocateFor Respondent: Shri R.Clement Ramesh –

Section 115BSection 132Section 134Section 69A

which could have been found during the course of search. Therefore, according to him, the cash found amounting to Rs.1,10,36,780/- was unexplained money and therefore, he taxed it u/s.69A of the Act and charging tax at the subject rate as per sec.115BBE of the Act. Aggrieved

G. Elumalai, Vellore vs. DCIT, Cengtral Circle-3(4), Chennai

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

ITA 1591/CHNY/2023[2021-21]Status: DisposedITAT Chennai05 Jul 2024AY 2021-21

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1591/Chny/2023 िनधा"रण वष" / Assessment Year: 2020-21 The Dy. Commissioner Of G. Elumalai V. Income Tax, 308/66, Bajani Koil Street, Central Circle -3(4), Alamelurangapuram, Chennai-34. Puduvasur, Vellore – 632 009. [Pan: Aaxpe-9401-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. M. Karunakaran, Advocate ""यथ" क" ओर से/Respondent By : Shri. V. Nandakumar, Cit सुनवाई क" तारीख/Date Of Hearing : 09.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.07.2024 आदेश /O R D E R

For Appellant: Shri. M. Karunakaran, AdvocateFor Respondent: Shri. V. Nandakumar, CIT

Section 131Section 132ASection 142(1)Section 143(2)Section 153ASection 69A

assessee is that sustaining the addition of Rs.22,89,925/- out of Rs.27,74,000/- being cash found during the search on 13.07.2019 as unexplained money :-2-: ITA. No: 1591/Chny/2023 u/s. 69A of the Income-tax Act, 1961 (hereinafter referred to as “the Act”). 3. The brief facts are that ... could not furnish any documentary evidence for the same. Since, the assessee failed to substantiate the source for cash, the same is treated as unexplained money. The case was notified to the Circle vide notification no. 20/2020-21 in C.No.831/PCIT-8/Cent & Decent/2020-21 dated 29.03.2021. The Assessing Officer noted that the assessee

Shan Exports, Mumbai vs. Central Circle 3(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 448/MUM/2024[2015-16]Status: DisposedITAT Mumbai05 Jul 2024AY 2015-16

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhrishan Exports Vs./ Central Circle (3)(4), 1/213, Navjivan Society, बनाम Mumbai Lamington Road, Room No. 1915, 19Th Floor, Mumbai-400008 Air India Bldg. Nariman Point, Mumbai-400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalfs008B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Ms. Mona SolankiFor Respondent: Shri Nagnath Pasale

Section 143(3)Section 148Section 148ASection 194ASection 250Section 251(1)Section 68Section 69A

circumstances of the case and in law, the Id. CIT(A) has erred in making addition of Rs. 37,75,000/- as unexplained money u/s 68 of the Income Tax Act, 1961. The said Addition is not in accordance with the provisions of the Act and as per the facts ... however, while confirming the addition the CIT(A) held the amount to be unexplained cash credit u/s 68 of the Act instead of unexplained money u/s 69A of the Act. 5. Before us, the Ld. AR has filed written submissions clarifying that