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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

Jaiswal Steel Industries Private Limited, Jamshedpur vs. ITO Ward 2(1), Jamshedpur

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

ITA 284/RAN/2024[2016-17]Status: DisposedITAT Ranchi19 Jan 2026AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.284/Ran/2024 Assessment Year: 2016-17 Jaiswal Steel Industries Pvt. Ltd. ….…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831006. [Pan: Aabcj4471C] Vs. Ito, Ward-2(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 02.04.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(3)Section 147Section 250Section 69Section 69A

Further, additions aggregating to ₹1,93,35,493 were made I.T.A. No.284/Ran/2024 Jaiswal Steel Industries Pvt. Ltd. on account of unexplained money under section 69A, unexplained investment under section 69 and disallowance of depreciation. 3. Aggrieved by the assessment order, the assessee preferred an appeal before the Commissioner of Income

Mohammed Wasim Akram, Madhepur, Barsoi, Katihar vs. ITO, Katihar

In the result, both the appeals are allowed for statistical purposes

ITA 465/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Sonjoy Sarmai.T.A. Nos.464&465/Pat/2025 Assessment Year: 2018-19 Mohammed Wasim Akram..……………… …………………....Appellant At/Po – Madhepur, Barsol, Ps-Telta, Katihar, Bihar- 854317.. [Pan: Bfcpa6650Q] Vs. Ito, Katihar……………….…..……………..………………….…..... Respondent Appearances By: Shri Nishant Gaurav, Ar, Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 आदेश / Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee & Are Directed Against Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Both Dated 14.08.2025. Ita No. 464/Patna/2025 Arises Out Of The Assessment Order Passed Under Section 147 Read With Section 144 Of The Income-Tax Act, 1961, Whereas

Section 144Section 147Section 148Section 271ASection 69A

section 144 of the Act and made an addition of ₹1,60,88,847/- under section 69A of the Act, treating the same as unexplained money. 3. Aggrieved, the assessee filed an appeal before the learned CIT(A). However, there was a delay of 9 months 27 days in filing

Mohammed Wasim Akram, Madhepur, Barsoi, Katihar vs. ITO, Katihar

In the result, both the appeals are allowed for statistical purposes

ITA 464/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Sonjoy Sarmai.T.A. Nos.464&465/Pat/2025 Assessment Year: 2018-19 Mohammed Wasim Akram..……………… …………………....Appellant At/Po – Madhepur, Barsol, Ps-Telta, Katihar, Bihar- 854317.. [Pan: Bfcpa6650Q] Vs. Ito, Katihar……………….…..……………..………………….…..... Respondent Appearances By: Shri Nishant Gaurav, Ar, Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 आदेश / Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee & Are Directed Against Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Both Dated 14.08.2025. Ita No. 464/Patna/2025 Arises Out Of The Assessment Order Passed Under Section 147 Read With Section 144 Of The Income-Tax Act, 1961, Whereas

Section 144Section 147Section 148Section 271ASection 69A

section 144 of the Act and made an addition of ₹1,60,88,847/- under section 69A of the Act, treating the same as unexplained money. 3. Aggrieved, the assessee filed an appeal before the learned CIT(A). However, there was a delay of 9 months 27 days in filing

Income Tax Office, Ludhiana vs. Rippan Dhir, Ludhiana

In the result, appeal of the Revenue stands dismissed

ITA 298/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh19 Jan 2026AY 2017-18

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 298/Chd/2025 "नधा"रण वष" / Assessment Year : 2017-18 Ito, Rippan Dhir, Ludhiana बनाम 247, New Hira Nagar St No. 2, Vs. Kakowal Road, Ludhiana 141008 "थायी लेखा सं./ Pan No: Agapd1957D अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing) "नधा"रती क" ओर से/Assessee By : None राज"व क" ओर से/ Revenue By : Sh. Rajat Kumar Kureel, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 05.01.2026 उदघोषणा क" तार"ख/Date Of Pronouncement : 19.01.2026 आदेश/Order Per Krinwant Sahay, Am :

For Appellant: NoneFor Respondent: Sh. Rajat Kumar Kureel, CIT DR
Section 144Section 251Section 251(1)Section 69ASection 69C

Appeals) has failed to appreciate the fact that the addition disallowance of Rs.1,65,28,500/- made by the AO on account of unexplained money u/s 69A r.w.s. 115BBE of the Income Tax Act, 1961. 5. That, the Ld. Commissioner of Income Tax (Appeals) has failed to appreciate the fact

Sandip Kailasappa Lakade, Parbhani vs. ITO, Ward, Range-27, Hingoli

In the result, the appeal filed by the assessee is dismissed

ITA 304/PUN/2025[2016-17]Status: DisposedITAT Pune19 Jan 2026AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

For Appellant: NoneFor Respondent: Shri Manish Mehta, Addl.CIT
Section 143(2)Section 144Section 147Section 148Section 148ASection 69A

upholding the validity of re-assessment proceedings and thereby confirming the addition of Rs.1,55,38,905/- made by the Assessing Officer as unexplained money u/s 69A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). 4. Facts of the case, in brief, are that the assessee ... assessment u/s 144 of the Act and made addition of Rs.1,55,38,905/- to the total income of the assessee being the unexplained money u/s 69A of the Act. 5. Before the Ld. CIT(A) / NFAC the assessee argued that the notice u/s 148 of the Act was issued

Kadubai Asaram Dalvi @ Anita Bhaskar Bankar, Aurangabad vs. Income Tax Officer Ward 1(2), Aurangabad

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

ITA 2332/PUN/2025[2017-18]Status: DisposedITAT Pune19 Jan 2026AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2332/Pun/2025 Assessment Year : 2017-18

For Respondent: Assessee by Shri Dhengle (virtual)
Section 143(2)Section 144Section 250Section 69

appear resulting into passing of the best judgment assessment u/s.144 of the Act and ld. AO has made the addition for ₹10.10 lakh for unexplained money u/s.69 of the Act. Ld. AO has also taken note of the CBDT Circular applicable for the Senior Citizens with regard to the demonetization

Nitin Harilal Shah, Mumbai vs. Income Tax Officer, Mumbai

ITA 6536/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 132Section 147Section 148Section 148ASection 151Section 153CSection 271(1)(c)Section 69A

issued show cause notices to examine the source of cash loan of Rs. 1,01,00,000/- as unexplained money u/s. 69A. In the absence of proper explanation, the AO assessed source of cash loan given to Sh. Nilesh Bharani amounting to Rs. 1,01,00,000/- as unexplained money

Balaram Nama Gaikwad, Mumbai vs. Income Tax Officer Ward 3(1), Mumbai

In the result, appeal of the assessee is allowed for

ITA 5129/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 148Section 234ASection 254(1)Section 69Section 69A

C.I.T (A) has erred in approving the action of the learned AO in making addition of Rs. 1,34,82,500/- as Unexplained Money U/s 69A, as cash deposited out of the total deposit of Rs. 1,40,22,500/- in Bank of Baroda account No. 27690400011066, already declared

Balaram Nama Gaikwad, Mumbai vs. Income Tax Officer Ward 3(1), Mumbai

In the result, appeal of the assessee is allowed for

ITA 5128/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 148Section 234ASection 254(1)Section 69Section 69A

C.I.T (A) has erred in approving the action of the learned AO in making addition of Rs. 1,34,82,500/- as Unexplained Money U/s 69A, as cash deposited out of the total deposit of Rs. 1,40,22,500/- in Bank of Baroda account No. 27690400011066, already declared

Incometax Officer-42(1)(3), Mumbai vs. Nipul Sureshchandra Mehta, Mumbai

ITA 4291/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Sanjay A. Thakkar &For Respondent: Assessee by
Section 144Section 69A

circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made of Rs. 1,20,6,499/- as unexplained money u/s. 69A of the I.T. Act, 1961 by the AO in respect of total credit deposits in the bank account of the assessee

Manishkumar Jadulal Thakkar, Rajkot vs. ITO Ward (1) (1), RKT, It-Office, New Aayakar Bhawan, Vatiaka, Rajkot

In the result, the appeal of the assessee is partly allowed, in above terms

ITA 12/RJT/2026[2012-13]Status: HeardITAT Rajkot16 Jan 2026AY 2012-13

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 12/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2012-13) Manishkumar Jadulal Thakkar The Ito, Wd-(1)(1) Rajin Infrastructure Shivam Park Sn 3, New Aayakar Bhavan, Vatiaka, Vs. Corner 150Ft Ring Road, Nr. Nagrik Rajkot-360001 Bank, Nr. Raiya Telephone Exchange, Rajkot – 360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adbpt5491J (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Suresh Tejwani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 131Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

bank account of the assessee to the tune of Rs. 7,00,000/- (Rs. 20,00,000 – Rs. 13,00,000) was treated as unexplained money within the meaning of section 69A of the Act and Page 4 of 9 Manishkumar J. Thakkar added to assessee's total income

Suresh Jat, Badnawar vs. The Income-Tax Officer, Dhar

Appeal is allowed for statistical purpose

ITA 693/IND/2025[2016-17]Status: DisposedITAT Indore16 Jan 2026AY 2016-17

Bench: Shri B.M. Biyani & Shri Paresh M Joshisuresh Jat, Ito, बनाम/ C/O S.V. Agrawal & Associate Dhar. Vs. Dadi Dham, 24-25, Joy Building Colony, Old Aplasia, Indore. (Pan: Anopj2666E) (Appellant) (Respondent) Assessee By Shri S.N. Agrawal, Ca Revenue By Shri Anup Singh, Cit-Dr Date Of Hearing 08.01.2026 Date Of Pronouncement 16.01.2026 आदेश/ O R D E R

Section 144(1)Section 147Section 148Section 148ASection 194ASection 194HSection 250Section 253Section 69A

income of the Assessee was computed & assessed at Rs. 9,84,35,092/-.No income tax return was filed. The addition on account of unexplained money u/s 69A rws 115BBE of the Act was at Rs. 9,80,10,563/-.There was yet another addition on the account of interest ... Hence, cash deposited amounting to Rs.9,80,10,563/- remained unexplained income of the assessee during the year and same is hereby treated as unexplained money under the ownership of the assessee u/s 69A of the Act. 2.8 In the impugned assessment order in para 5 it is recorded

Radheshyam Agarwal, Bhopal vs. The PCIT, Central, Bhopal

ITA 417/IND/2025[2018-19]Status: DisposedITAT Indore16 Jan 2026AY 2018-19

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

Section 115BSection 133ASection 143(2)Section 147Section 148Section 148ASection 253Section 263

does not show that the same was part of his business. In view of the above facts as discussed above, it is evident that unexplained money of Rs.49,82,740/-(οι 740/-(on account of interest income earned in earlier year) and unexplained investment in stock of Rs.23

Kalpana Narware, Betul vs. Income Tax Officer, Betul

Appeal is allowed for statistical purpose

ITA 202/IND/2025[2017-18]Status: DisposedITAT Indore16 Jan 2026AY 2017-18

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

Section 144Section 253

## आयकर अपीलीय अिधकरण**,** इंदौर Ɋायपीठ**,** इंदौर **IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE** ### **BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Kanubhai Maganbhai Patel, Anand vs. ITO, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 1404/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2012-13

Bench: Ms. Suchitra Kambleassessment Year 2012-13

For Appellant: Shri Parin Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 148Section 234ASection 271(1)(c)Section 69A

Despite giving statutory notices, the assessee has not responded the said notices. Therefore, the Assessing Officer made addition of Rs. 11,01,694/- as unexplained money u/s. 69A of the Act. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed

Pallapu Srinivasarao (HUF), Almasguda vs. ITO., Ward-9(1), Hyderabad

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

ITA 1586/HYD/2025[2020-21]Status: DisposedITAT Hyderabad16 Jan 2026AY 2020-21

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

Section 139(1)Section 144Section 147Section 148Section 148ASection 69A

come forth with any explanation regarding the source of the credits in his aforementioned bank account, therefore, the AO held the same as his unexplained money under section 69A of the Act. Accordingly, the 4 Pallapu Srinivasa Rao (HUF) vs. ITO AO vide his order under section 147 r.w.s

Mohd Shoaib Ur Rahman, Hyderabad vs. Income Tax Officer, Ward-4(1), Hyderabad

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

ITA 1561/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad16 Jan 2026AY 2015-2016

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

Section 147Section 148Section 148ASection 149Section 69A

NFAC and 4 the Assessing officer have erred in making an addition of Rs 1,33,40,906 U/s 69A of the Act as unexplained money 5)The Ld. Commissioner of Income Tax (Appeals), NFAC and 5 the Assessing officer have failed to take cognizance of and appreciate the evidence

Atma Ram Builders Private Limited, New Delhi vs. Income Tax Officer, Central Circle 5, New Delhi

In the result, appeal of the Assessee is allowed in above terms

ITA 3593/DEL/2025[A.Y. 2020-21]Status: DisposedITAT Delhi16 Jan 2026

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 143(3)Section 263Section 269TSection 270ASection 271ESection 69ASection 80G

assessee has not explained the said balance amount and has not filed reconciliation statement. Hence, accordingly treated as unexplained money u/s 69A of the Act. With regard to the interest expenses paid to M/s. Atma Ram Trust to the extent of Rs. 10,48,480/-. According

Zia Rathi, Delhi vs. Income Tax Officer Ward-44(3), Delhi

In the result, appeal filed by the assessee is allowed

ITA 1881/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalmrs. Zia Rathi, Income Tax Officer, 274, Dda Flats, Sector-1A, Ward-44(3), Dwarka Nasirpur, Vs. Delhi. New Delhi-110045. Pan-Bsvpr9218M (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. Shri Saksham Agarwal, Ca & Shri Deepesh Garg, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 04/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 27.02.2024 In Appeal No. Cit(A), Delhi- 15/11146/2019-20 Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’ For Short) For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is Sole Proprietor Of M/S Veezee Traders Engaged In The Business Of Trading Of Pvc Coated Imported Fabric. The Zia Rathi Vs. Ito

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 234BSection 68

controvert such details nor any defects were pointed out thus merely on assumption, it cannot be held that cash deposited during demonetization is unexplained money of the assessee. Accordingly, we hereby direct the AO to delete the addition made u/s 68 of the Act towards the cash deposited during demonetization

ACIT, Agra vs. Saurabh Gupta, Agra

In the result, the appeals of the Revenue, ITA No

ITA 166/AGR/2025[2015]Status: DisposedITAT Agra15 Jan 2026

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 132Section 143(3)Section 250(6)Section 271DSection 271ESection 69A

account of cash loans received and Rs.1,19,60,000/- on account of repayment of such loans in cash, treating the same as unexplained money under section 69A of the Act. Consequent thereto, the Assessing Officer initiated penalty proceedings under sections 271D and 271E of the Act for contravention