← All Phrases

“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

Bhagyeshree Chandrashekar Sakle, Pune vs. ITO, Ward-9(3), Pune

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

ITA 2337/PUN/2025[2020-21]Status: DisposedITAT Pune27 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2337/Pun/2025 निर्धारण वषा / Assessment Years: 2020-21 Bhagyeshree Chandrashekar V The Income Tax Officer, Sakle, S Ward-9(3), Pune. Shop No.511, Cantonment Complex, Dehuroad, Ral Haveli, Pune – 412101. Pan: Cqyps6464G Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 22/01/2026 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 12.09.2025 For A.Y.2020-21 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Read With Section 144B Of The Income-Tax Act, 1961 Dated 17.01.2025. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 144BSection 147Section 148Section 250Section 69A

circumstances of the case and in law, Ld. AO erred in making an addition of Rs.2,31,73,455/- u/s 69A r.w.s 11588E- Unexplained Money, given an opportunity, your appellant is in position to explain the details of deposits and anyway these cash deposits were made on behalf of bank

Sapana Dharmendra Shah, Malegaon vs. The Income Tax Officer, Ward -1, Malegaon

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

ITA 2217/PUN/2025[2018-19]Status: DisposedITAT Pune27 Jan 2026AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2217/Pun/2025 धििाारण वर्ा / Assessment Year : 2018-19 Sapana Dharmendra Shah, The Income Tax Officer, Khodiyar Bhavan, Ramsetu, Ward – 1, Malegaon Opp. Gayatri Mangal Karyala, Vs. Malegaon, Nashik-423203 Pan : Belps3009B अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sanjeev Mutha (Virtual) Department By : Shri Manish Mehta Date Of Hearing : 20-01-2026 Date Of 27-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 22.08.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2018-19. 2. Briefly Stated The Facts Are That The Assessee Is An Individual & Did Not File His Return Of Income For Ay 2018-19. Based On The Information Flagged By The Cbdt Through Insight Portal Under The Head “Nms Category”, It Was Found That During The Relevant Ay 2018-19, The Assessee Had Deposited Cash Of Rs.2,91,03,000/- In Her Bank Account Maintained With The Malegaon Merchant‟S Co-Op Bank Ltd. In The Name Of M/S Shree Kakaji Masale & Foods. Further, There Is Also Tds Made To The Tune Of Rs.1,524/- U/S 194A Of The Income Tax Act, 1961 (The “Act”) On „Interest Other Than „Interest On Securities‟ Against A Total Credit Of Rs.15,240/- By The Malegaon Merchant‟S Co-Op Bank Ltd., Which Has Not Been Disclosed To The Department. Since, The Assessee Had Not Filed Her Return Of Income, Notice U/S 148 Of The Act Was Issued On 05.04.2022 Which Was Duly Served Upon The Assessee. In Response Thereto, The Assessee Did Not File Her Return Of Income. Thereafter, Notice U/S 142(1) Of The Act As Well As Show Cause Notice Were Issued, In Response To Which The Assessee Filed Certain

For Appellant: Shri Sanjeev Mutha (Virtual)For Respondent: Shri Manish Mehta
Section 142(1)Section 147Section 148Section 148ASection 194ASection 69A

case and as per law, the assessing officer is not justified in making an addition of Rs. 2,99,99,003/- account of unexplained money by invoking section 69A when the provisions of section 69A are not applicable in the present case. 5. On the basis of facts

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, captioned appeals filed by the assessee are allowed for statistical purpose

ITA 3387/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Jan 2026AY 2018-19

Bench: Hon’Ble Ms. Padmavathy S & Hon’Ble Shri Manu Kumar Giri

For Appellant: Mr. R. Venkata Rama, CAFor Respondent: Ms. Gouthami
Section 147Section 249(2)Section 271(1)(c)Section 69Section 69A

case: The Assessing Officer (AO) assessed the income u/s.147 r.w.s. 144 r.w.s 144B of the Income Tax Act 1961 on account of unexplained money u/s.69A and unexplained investment u/s.69. The (AO) also initiated the penalty proceedings u/s 271(1)(c), and 271AAC. Similar additions and penalties are levied in other

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, captioned appeals filed by the assessee are allowed for statistical purpose

ITA 3386/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Jan 2026AY 2017-18

Bench: Hon’Ble Ms. Padmavathy S & Hon’Ble Shri Manu Kumar Giri

For Appellant: Mr. R. Venkata Rama, CAFor Respondent: Ms. Gouthami
Section 147Section 249(2)Section 271(1)(c)Section 69Section 69A

case: The Assessing Officer (AO) assessed the income u/s.147 r.w.s. 144 r.w.s 144B of the Income Tax Act 1961 on account of unexplained money u/s.69A and unexplained investment u/s.69. The (AO) also initiated the penalty proceedings u/s 271(1)(c), and 271AAC. Similar additions and penalties are levied in other

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, captioned appeals filed by the assessee are allowed for statistical purpose

ITA 3385/CHNY/2025[2016-17]Status: DisposedITAT Chennai27 Jan 2026AY 2016-17

Bench: Hon’Ble Ms. Padmavathy S & Hon’Ble Shri Manu Kumar Giri

For Appellant: Mr. R. Venkata Rama, CAFor Respondent: Ms. Gouthami
Section 147Section 249(2)Section 271(1)(c)Section 69Section 69A

case: The Assessing Officer (AO) assessed the income u/s.147 r.w.s. 144 r.w.s 144B of the Income Tax Act 1961 on account of unexplained money u/s.69A and unexplained investment u/s.69. The (AO) also initiated the penalty proceedings u/s 271(1)(c), and 271AAC. Similar additions and penalties are levied in other

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, captioned appeals filed by the assessee are allowed for statistical purpose

ITA 3384/CHNY/2025[2015-16]Status: DisposedITAT Chennai27 Jan 2026AY 2015-16

Bench: Hon’Ble Ms. Padmavathy S & Hon’Ble Shri Manu Kumar Giri

For Appellant: Mr. R. Venkata Rama, CAFor Respondent: Ms. Gouthami
Section 147Section 249(2)Section 271(1)(c)Section 69Section 69A

case: The Assessing Officer (AO) assessed the income u/s.147 r.w.s. 144 r.w.s 144B of the Income Tax Act 1961 on account of unexplained money u/s.69A and unexplained investment u/s.69. The (AO) also initiated the penalty proceedings u/s 271(1)(c), and 271AAC. Similar additions and penalties are levied in other

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, captioned appeals filed by the assessee are allowed for statistical purpose

ITA 3383/CHNY/2025[2014-15]Status: DisposedITAT Chennai27 Jan 2026AY 2014-15

Bench: Hon’Ble Ms. Padmavathy S & Hon’Ble Shri Manu Kumar Giri

For Appellant: Mr. R. Venkata Rama, CAFor Respondent: Ms. Gouthami
Section 147Section 249(2)Section 271(1)(c)Section 69Section 69A

case: The Assessing Officer (AO) assessed the income u/s.147 r.w.s. 144 r.w.s 144B of the Income Tax Act 1961 on account of unexplained money u/s.69A and unexplained investment u/s.69. The (AO) also initiated the penalty proceedings u/s 271(1)(c), and 271AAC. Similar additions and penalties are levied in other

Karuppanna Gounder Paramasivam, Erode vs. DCIT, Circle-1, Erode

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

ITA 3363/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Jan 2026AY 2017-18

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Appellant: MR. S. Senthil Kumar, Adv
Section 143(3)Section 14ASection 69

other sources. 3. The Assessment Order has been passed u/s.143(3) dated 23.12.2019 making an addition of Rs.92,36,863.00/- u/s 69(A) being unexplained money. 4. The Learned AR for the Assessee has challenged the Assessment Order before the CIT(A). The Learned CIT(A) vide its order dated

Mani Sridhar, Chennai vs. CIT (A), Chennai

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

ITA 3292/CHNY/2025[2016-2017]Status: DisposedITAT Chennai27 Jan 2026AY 2016-2017

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

Section 115BSection 142(1)Section 144Section 147Section 148Section 69A

explanation, the AO inferred that the appellant had no substantiating evidence and that the entire amount of Rs. 1,82,35,029/- represented unexplained money. The AO therefore added Rs.1,82,35,029/- to total income u/s 69A, taxable under section 115BBE, and completed the assessment u/s 144/147 r.w.s. 144B

Thirumoorthy Revathi, Coimbatore vs. ITO, Ncw-4(4), Coimbatore

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

ITA 3188/CHNY/2025[2015-16]Status: DisposedITAT Chennai27 Jan 2026AY 2015-16

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3188/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 133(6)Section 148Section 148ASection 149Section 149(1)Section 250Section 69A

brother-in-law, who denied having made such payments to the assessee. Hence, the AO added the sum of Rs.29,30,000/- as unexplained money u/s.69A of the Act along with the amount disclosed of Rs.3,66,190/- declared by the assessee in the invalid return. 3. Aggrieved

DCIT-CC-8(4), Mumbai vs. Akshay Jayantilal Doshi, Mumbai

ITA 6136/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokardcit-Cc-8(4), Akshayjayantilaldoshi Mumbai 701, Bhoomibldg, Jvpd Room No. 658, 6Th Vs. Scheme Vileparle, Floor, Mumbai- 400056 Aayakarbhawan, Mumbai- 400020, Mumbai Pan/Gir No. Aahpd2867K (Applicant) (Respondent) Assessee By Shri Akshay Jain Revenue By Shrisurendra Mohan, Sr. Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 27.01.2026 आदेश / Order Per Makarand Vasant Mahadeokar,Am: This Appeal Is Filed By The Revenue Against The Order Passed By The Learned Commissioner Of Income-Tax (Appeals)–50, Mumbai [Hereinafter Referred To As “Cit(A)”], Dated 31.07.2025, For Assessment Year 2022–23, Whereby The Learned Cit(A) Deleted The Addition Of Rs. 1,25,64,000/- Made By The Assessing Officer Under Section 69A Of The Income-Tax Act, 1961[Hereinafter Referred To As “The Act”] Vide Order Dated 02.06.2023 Passed Under Section 143(3) Of The Act.

Section 115BSection 132Section 143(3)Section 69A

afterthought. 6. Accordingly, the Assessing Officer treated the cash of Rs. 1,25,64,000/- found at the residence of the assessee as unexplained money under section 69A of the Act and added the same to the total income of the assessee. The said addition was taxed under section 115BBE

Diamond Tradecom Private Limited, Mumbai vs. Income Tax Officer Ward 12(2)(1), Mumbai

In the result, the appeal of assessee is allowed

ITA 5850/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Jan 2026AY 2016-17

Bench: Shri Pawan Singh(Physical Hearing) Diamond Tradecom Private Limited Ito,Ward-12(2)(1), Mumbai Shop No. 1, Shiv Ganga Chs Ltd., Vs Room No. 147B, Aayakar Bhavan, Ram Kuwar Thakur Road, M.K. Road, Dahisar (East), Mumbai – 400020. Mumbai – 400068. [Pan No. Aaccd8131A] Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 149(1)(a)Section 151Section 250Section 250(6)Section 254(1)Section 69A

erred in the confirming the addition of Rs.3,07,000/- u/s 69A of the IT Act.,1961 made by the Ld. AO being unexplained money as investment in equity shares. 7. On the facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition

Priya Enterprise, Vapi vs. ITO, Ward-7, Vapi

In the result, the appeal of the assessee is allowed

ITA 800/SRT/2025[2010-11]Status: HeardITAT Surat23 Jan 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Raghunath Kamble

For Appellant: Shri Rajesh Upadhyay, ARFor Respondent: Ms Namita Patel, Sr. DR
Section 250

Assessment Year 2016-17. Ground No.2: 2. The Assessing Officer made addition of Rs.15,12,000/-, being cash deposited in HDFC Bank account as unexplained money for want of documentary evidence. The Ld. CIT(A) confirmed the addition observing that the assessee had not furnished supporting evidence during assessment

Jayendrakumar Jayantibhai Rafaliya, Surat vs. ITO, Ward-3(2)(1), Surat

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

ITA 997/SRT/2024[2018-19]Status: HeardITAT Surat23 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblejayendrakumar Jayantibhai The Income Tax Officer, Vs. Rafaliya, Ward-3(2)(1) F-3, Ishwarkrupa Society, Surat. Katargam Road, Gotla Wadi, Surat-395004. [Pan :Akxpr8256 J] (Appellant) .. (Respondent) Appellant By : Shri Mehul K Patel, Ar Respondent By: Shri Ashish Kumar, Sr. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 23.01.2026

For Appellant: Shri Mehul K Patel, ARFor Respondent: Shri Ashish Kumar, Sr. DR

records, it is observed that the assessee was afforded several opportunities of hearing to furnish details, clarifications, and explanations to substantiate the source of unexplained money. However, despite being granted multiple opportunities, the assessee remained non-compliant and failed to furnish the requisite details or Asst. Year

Pragjibhai Parshotambhai Patel, Na vs. Arivs.Income Tax Officer, Ward-4, Navsari

In the result, the appeal of the assessee is allowed

ITA 858/SRT/2024[2014-15]Status: HeardITAT Surat23 Jan 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 250Section 44ASection 50C

maintaining regular books of account. No material has been brought on record before us by the Revenue to establish that the impugned amount represented unexplained money of the assessee. Therefore, the addition of Rs.10,00,000/- is unsustainable and is directed to be deleted. 6. With regard to the addition

Sureshbhai Popatlal Patel L/H Sohankumar Sureshkumar Patel, Vapi vs. ITO, Ward 8, Vapi

In the result, the appeal of the assessee is allowed

ITA 1337/SRT/2024[2007-08]Status: HeardITAT Surat23 Jan 2026AY 2007-08

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 250Section 69A

documentary evidence regarding the alleged cash receipts from friends and relatives, the Assessing Officer treated the aggregate amount of Rs. 7,83,000/- as unexplained money u/s 69A of the Act and added the same to the total income. 4. Aggrieved by the order of the Assessing Officer, the assessee

Prakash Reddy Vatti, Hyderabad vs. ITO, Ward-11(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1806/HYD/2025[2015-16]Status: DisposedITAT Hyderabad23 Jan 2026AY 2015-16

Bench: Shri Vijay Pal Raoआ.अपी.सं /Ita No.1806/Hyd/2025 Assessment Year 2015-2016 Vatti Prakash Reddy, The Income Tax Officer, Hyderabad – 500 018. Ward-11(1), Hyderabad. Vs. Telangana. Pin – 500 017. Pan Aaspv8120C Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca A Vamseedhar राज" व "ारा /Revenue By: Ms P Sumitha, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.01.2026 घोषणा की तारीख/Pronouncement: 23.01.2026 आदेश/Order

For Appellant: CA A VamseedharFor Respondent: MS P Sumitha, Sr. AR
Section 115BSection 144B(7)(vii)Section 148Section 148ASection 149(1)(b)Section 151Section 151ASection 250(6)Section 69A

./2025 reasons or independent verification, contrary to the principles of Natural Justice. 5. That the Assessing Officer wrongly treated Rs. 25,27,000 as unexplained money under Section 69A despite the appellant having discharged the initial onus by substantiating the source through credible evidence, thereby misapplying Section 115BBE; such addition

Anitha Kotamraju, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, appeal of the Assessee is Partly

ITA 1692/HYD/2025[2013-14]Status: DisposedITAT Hyderabad23 Jan 2026AY 2013-14

Bench: Shri Vijay Pal Rao

For Appellant: Sri D Prabhakar Reddy, AdvocateFor Respondent: MS P Sumitha, Sr. AR
Section 147Section 148Section 194HSection 69A

circumstances of the case and in law, the Ld. CIT(A) erred in confirming action of AO for making addition u/s 69A as unexplained money when the amount of Rs.43,71,193/- was received as sub-brokerage commission from BN Rathi Comtrade Pvt. Ltd and thus explained

G K Properties Private Limited, Hyderabad vs. Income Tax Officer, Ward-2(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1465/HYD/2025[2020-21]Status: DisposedITAT Hyderabad23 Jan 2026AY 2020-21

Bench: Shri Vijay Pal Rao

For Appellant: CA Alok AgarwalFor Respondent: MS P Sumitha, Sr. AR
Section 143(3)Section 69A

Hence, the addition is liable to be deleted. 4. The Learned Commissioner of Income Tax Appeals has erred in treating Rs.20,00,000/- as unexplained money u/s. 69A of the Income Tax Act, 1961 which was paid towards outstanding amount on account of purchase of property. This addition is liable

Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Periyasamy Anbunathan, Karur

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

ITA 1596/CHNY/2025[2016-17]Status: DisposedITAT Chennai23 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.J.K. Reddy, CAFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 131Section 132Section 132(4)Section 250

आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक