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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

Navyug Nirman Shaikshanik Sansthan, Patna vs. ACIT, Circle-1, Patna

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

ITA 477/PAT/2025[2018-19]Status: DisposedITAT Patna15 Jan 2026AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Sonjoy Sarmai.T.A. No.477/Pat/2025 Assessment Year: 2018-19 Navyug Nirman Shaikshanik Sansthan. …………………....Appellant Guru Kripa, Shiv Raj Yadav Path, Mohanpur, Punaichak, Po- L B S Nagar, Patna, Bihar- 800023. [Pan: Aaefn5170A] Vs. Dcit, Cc-1, Patna………….…..……………..………………….…..... Respondent Appearances By: Shri Vishal Kr. Adv. Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 13, 2026 Date Of Pronouncing The Order : January 15, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 29.08.2025 Passed By The Cit(A)-3, Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Is A Firm & Had Not Filed Its Return Of Income For The Assessment Year 2018-19. An Information Was Received By The Assessing Officer That The Assessee Has Deposited Cash Of Rs.1,10,77,405/- In The Bank Account During The Relevant Assessment Year. As There Was Reason To Believe That The Amount Of Rs. 1,10,77,405/- Was Escaped Assessment, The Case Of The

Section 147Section 148Section 250Section 69A

said notice and did not file any return of income in response to said notice. The Assessing Officer treated the cash deposits as unexplained money u/s 69A of the Act and added the same to the total income of the assessee. 3. Aggrieved by the assessment order, the assessee preferred

Chandra Prakash Jain, Uttarpradesh vs. DCIT Central Circle -20, Delhi

In the result the appeal of the assessee is hereby

ITA 5296/DEL/2025[2022-23]Status: DisposedITAT Delhi15 Jan 2026AY 2022-23

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5296/Del/2025 : Asstt. Year : 2022-23 Sh. Chandra Prakash Jain, Vs Dcit, 308, Augusta Town Homes, Sector- Central Circle-20, 128, Jp Wishtown Noida, Maharishi New Delhi Nagar, Sultanpur, Gautam Buddha Nagar, Uttar Pradesh-201304 (Appellant) (Respondent) Pan No. Aakpj0890M Assessee By : Sh. Ved Jain, Adv., Sh. Pawan Garg, Ca & Ms. Ishika Dua, Ca Revenue By : Ms. Amish S. Gupt, Cit-Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2022-23, Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024–25/1075064329(1) Dated 26.03.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ved Jain, AdvFor Respondent: Ms. Amish S. Gupt, CIT-DR
Section 132Section 143(3)Section 69A

coming from both the parties that the CIT(A) has upheld the assessment findings dated 12.03.2024 treating the assessee’s 2 Chandra Prakash Jain unexplained money representing jewellery of Rs.37,47,492/-; reading as under: “4. On perusal of the appellate record and submission filed it is noted that ... also pertinent to mention that the appellant has also submitted its submission only with regard to addition to its income on account of unexplained money being seized jewellery. Hence, all the grounds of appeal are hereby adjudicated altogether. 4.1 The assessee is an individual person, he filed his return

Sharda Devi, Basti vs. Income Tax Officer, Basti

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

ITA 525/LKW/2025[2017-18]Status: DisposedITAT Lucknow13 Jan 2026AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Sharda Devi, Vs. The Income Tax Officer, W/O Shyam Singh, Near Zila Basti-New Chikitsalaya, Purani Basti, Basti-2721 Pan: Auspd8424B (Appellant) (Respondent) Assessee By: None Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.10.2025 Date Of Pronouncement: 13.01.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 16.01.2025 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Of Penalty Passed By The Ld. Ao Dated 17.01.2022 In Limine Without Going Into The Merits Of The Case. The Grounds Of Appeal Are As Under:- “01. Because The Cit(A) Has Erred On Facts & In Law In Upholding The Addition Of Rs.8,11,663/- Being Cash Deposited In Bank During Demonetization Period Under Section 69A R.W.S. 115Bbe Of The Act, Which Addition Is Contrary To Facts, Bad In Law Be Deleted. 02. Because The Cit(A) Has Failed To Appreciate That The Assessee Is Carrying On The Business Of Household Items, Such As, Business Of Achar, Kuchry (Grocery) Declaring Profit Under Section 44Ad @ 8% Wherein The Provisions Of Section 68 & Section 69 Are Not Applicable, The Addition Of Rs.8,11,663/- Made By The Ao & Upheld By The Cit(A) Is Contrary To The Provisions Of Law Be Deleted. 03. Because The Explanation Furnished By The Assessee Has Not Been Found False Of Untrue, The Addition Of Rs.8,11,663/- Made By The Ao & Upheld By The Cit(A) Be Deleted.”

For Appellant: NoneFor Respondent: Sh. Amit Kumar, DR
Section 115BSection 147Section 271ASection 44ASection 68Section 69Section 69A

explained and the remaining amount of Rs. 8,11,663/- deposited in the aforesaid bank account during the demonetization was unexplained money under section 69A. He, therefore, brought the same to tax @ 60% under section 115BBE. He also added back the interest received on these deposits

M/S. Aryan Share and Stock Brockers Limited, Chennai vs. ITO, Corp Ward-1, Chennai

In the result, Appeal filed by the assessee is allowed

ITA 2115/CHNY/2025[2014-15]Status: DisposedITAT Chennai13 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No. 2115/Chny/2025 "नधा"रण वष"/Assessment Year: 2014-15 M/S Aryan Share & Stock Brokers V. Ito Corp Ward-1, Limited., Itd, M G Road, No. 07, 07Th Cross Street, Nungambakkam, 2Nd Floor, Shreeji Metropolis, Chennai-600034 Aminjikarai, Chennai-600030 Tamil Nadu Tamil Nadu [Pan:Aadca 1233 H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Assessee By : Mr. Y Sridhar, Ca ""यथ" क" ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 10.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 13.01.2026

For Appellant: Mr. Y Sridhar, CAFor Respondent: Ms. Anitha, Addl.CIT
Section 147Section 69A

u/s.69A in respect of losses incurred by the assessee in trading in the shares of M/s. Looks Health Services Limited. Losses can never be unexplained money by any stretch of imagination and hence submitted that no addition u/s 69A can be made in the instant case. (f) The transaction ... books of account and for which no satisfactory explanation is offered. In the instant case, what has been brought to tax is not any unexplained money but a trading loss incurred by the assessee in the course of equity/derivative transactions carried out through a recognised stock exchange. The assessee