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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

Vijay Kumar, Samastipur vs. ITO, Ward 3 (3), Samastipur

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

ITA 79/PAT/2025[2017-18]Status: DisposedITAT Patna09 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.79/Pat/2025 Assessment Year: 2017-18 Vijay Kumar………..………….………………. …………………....Appellant Kishanpur Warish Nagar, Samastipur, Bihar-848101. [Pan: Aqcpk3836C] Vs. Ito, Ward-3(3), Samastipur…....……………..………………….…..... Respondent Appearances By: Shri G. P. Tulsiyan, Fca, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 08, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 29.01.2025 Passed By The Nfac, Delhi U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee, An Individual, Filed His Return Of Income For The Assessment Year 2017–18 Declaring A Total Income Of ₹3,51,040. Subsequently, The Case Of The Assessee Was Selected For Scrutiny Assessment & Notice Under Section 143(2) Of The Income-Tax Act, 1961 Was Duly Issued. During The Course Of Assessment Proceedings, The Assessing Officer Noticed Cash Deposits Of ₹20,00,000 In The Assessee’S Bank Account. The Assessing Officer Provided Several

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

documentary evidence. Accordingly, the assessment was completed under section 143(3) of the Act, and an addition of ₹20,00,000 was made as unexplained money under section 69A of the Act. 3. Aggrieved by the assessment order, the assessee preferred an appeal before

Sanddep Tiwari, West Champaran vs. ITO Ward 1(5), Bettiah, West Champaran

In the result, the appeal of the assessee is allowed to the extent indicated above

ITA 255/PAT/2025[2017-2018]Status: DisposedITAT Patna09 Jan 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.255/Pat/2025 Assessment Year: 2017-18 Sandeep Tiwari..…………….………………. …………………....Appellant Vill: Alitolla, Po Thakraha, Via Nechua Jalalpur, West Champaran, Bettiah, Bihar- 841503.. [Pan: Apopt9064Q] Vs. Ito, Ward-1(5), Bettiah…....…..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singla, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 08, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 24.05.2025 Passed By The Nfac, Delhi U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That As Per Information Available On The Aims Module Of The Income-Tax Department, It Was Noticed That During The Period 09.11.2016 To 30.12.2016 (Demonetisation Period), The Assessee Had Made Cash Deposits Of ₹10,00,000 In His Bank Account Maintained With Bank Of India. Accordingly, Notice Under Section 142(1) Of The Income-Tax Act, 1961 Along With A Questionnaire Was Issued. Since There Was Non-Compliance On The Part Of The Assessee, A Final

Section 115BSection 142(1)Section 144Section 250Section 69A

show-cause notice was issued. In the absence of any response, the Assessing Officer treated the entire cash deposit of ₹10,00,000 as unexplained money under section 69A, taxable under section 115BBE, and completed the assessment under section 144 of the Act. Thus, the total income of the assessee ... determined by estimating profits on turnover, the profit element alone is brought to tax. In such circumstances, the provisions of section 69A relating to unexplained money cannot be simultaneously applied. The income so assessed as the character of business income and is liable to be taxed under the normal provisions

Rajesh Kumar Sah, Muzaffarpur vs. ITO, Ward- 1 (1), Muzaffarpur

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

ITA 165/PAT/2025[2018-19]Status: DisposedITAT Patna09 Jan 2026AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.165/Pat/2025 Assessment Year: 2018-19 Rajesh Kumar Sah.………….………………. …………………....Appellant C/O Harilal Prasad Navanagar, Nijamat, Karnowl, Sahebgunj, Muzaffarpur-843125. Bihar.. [Pan: Efwpk4178C] Vs. Ito, Ward-1(1), Muzaffarpur…..……………..………………….…..... Respondent Appearances By: Shri G. P. Tulsiyan, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 04.02.2025 Passed By The Nfac, Delhi 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 Did Not File His Return Of Income For The Assessment Year 2018–19. Consequently, Notice Under Section 148 Of The Act Was Issued. However, Even In Response To The Notice Under Section 148, The Assessee Failed To File The Return Of Income. During The Reassessment Proceedings, On Verification Of Bank Accounts, The Assessing Officer Noticed Cash Deposits Aggregating To ₹3,26,54,960, Which Were Treated As Unexplained Money Under Section

Section 148Section 250

reassessment proceedings, on verification of bank accounts, the Assessing Officer noticed cash deposits aggregating to ₹3,26,54,960, which were treated as unexplained money under section I.T.A. No.165/Pat/2025 Rajesh Kumar Sah 69A of the Act and added to the total income of the assessee and the assessing Officer completed ... banking correspondence activities. 4. It was submitted that the deposits represented business transactions carried out on behalf of IDFC Bank Limited and not unexplained money of the assessee. However, the Ld. CIT(A) confirmed the addition, without examining the above factual contentions in detail. 5. Dissatisfied with the order

Yadagiri Gurram, Nalgonda vs. Income Tax Officer, Ward-1, Nalgonda

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

ITA 1214/HYD/2025[2017-18]Status: DisposedITAT Hyderabad09 Jan 2026AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी. सं / Ita No.1214/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2017-18) Shri Yadagiri Gurram Nalgonda Pan:Bdrpg9128G (Appellant) Vs. Income Tax Officer Ward 1 Nalgonda (Respondent) निर्धारिती द्वारा / Assessee By: Adv. Dayakar राजस्व द्वारा / Revenue By: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख / Date Of Hearing: 05/01/2026 घोषणा की तारीख / Pronouncement: 09/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Yadagiri Gurram, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 30.05.2025 For The A.Y 2017-18.

For Appellant: Adv. DayakarFor Respondent: Shri Madhukar AVES, Sr. DR
Section 142(1)Section 144Section 234ASection 234BSection 271ASection 271FSection 69A

bank accounts. In the absence of any explanation from the assessee, the Ld. AO treated the entire cash deposits as unexplained money under section 69A of the Act and completed the assessment under section 144 of the Act vide order dated 06.12.2019, assessing the total income of the assessee

Maulana Azad College of Engineering and Technology, Patna vs. ITO Exemption, Ward-1, Patna

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

ITA 474/PAT/2025[2015-16]Status: DisposedITAT Patna08 Jan 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Years: 2015-16 Maulana Azad College Of Engineering & Technology..…..……….……Appellant Mariam, Manzil, Anisabad, Patna-800002.. [Pan: Aabtm3371M] Vs. Ito-Exemption, Ward-1, Patna…...…………………….....……...…..…..Respondent Appearances By: Shri D V Pathy, Sr. Adv., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2025 Date Of Pronouncing The Order : January 08, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.08.2025 Of The Nfac, Delhi (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Are That The Assessee Is An Educational Institution & Is Engaged In The Activity Of Running In Engineering College & The Assessee-Society Is Registered Under Section 12Aa Of The Act. Thereafter, The Assessing Officer Issued Notice U/S 148 Of The Act On The Ground Of Certain Transactions & Cash Deposits Exceeding Two Lakhs Done By The Assessee With State Bank Of India. The Assessing Officer Held That The Deposits Made In The Sbi Was Not Disclosed & The Same Was Held As Unexplained Money & The Assessing Officer Made Addition Of Rs.56,79,506/- U/S 69A Of The Act. Maulana Azad College Of Engineering & Technology 3. Aggrieved By The Said Order, The Assessee Preferred An Appeal Before The Ld. Cit(A) Wherein The Appeal Has Been Dismissed By Holding That The Assessee Failed To File Supporting Documents Such As Balance Sheets, Profit & Loss A/C, Bank Statements Etc. To Prove The Genuineness Of The Transaction.

Section 12ASection 148Section 250Section 69A

State Bank of India. The Assessing Officer held that the deposits made in the SBI was not disclosed and the same was held as unexplained money and the Assessing Officer made addition of Rs.56,79,506/- u/s 69A of the Act. Maulana Azad College of Engineering and Technology 3. Aggrieved