“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

Shri K.D.Parmar, Incometax Officer, Ward-3(3)(1), Ahmedabad vs. Dharmesh Rajnikant Trivedi, Ahmedabad

In the result, the appeal filed by the Revenue is treated as allowed for statistical purpose

ITA 178/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115BSection 143(3)Section 148Section 148ASection 69A

accepted by the assessing officer, therefore the credit entries in the bank accounts aggregating to Rs. 4,78,08,900/- is added as the unexplained money u/s. 69A and also taxed u/s. 115BBE of the Act. 3. Aggrieved against the assessment order, the assessee filed an appeal before ... commission income earned out during the normal course of business, out of total addition of Rs.4,70,08,359/made by AO on account of unexplained money u/s. 69A r.w.s. 115BBE of the Act ignoring that: (i) The assessee has failed to furnish any satisfactory reply or supporting documents to establish

Sulbha Chakrapani Sarvade, Pune vs. Income Tax Officer, Ward 2, Sangli

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

ITA 1619/PUN/2025[2018-19]Status: DisposedITAT Pune08 Jan 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1619/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Umesh MaliFor Respondent: Shri Amit Bobde

Section 147Section 44Section 69A

mistake of my accountant she failed to file return of income 1.2) Learned A.O. has made an addition of Rs.8,38,85,410/-being unexplained money u/s 69A of The Income Tax Act 1961. As per following details Cash deposit in bank of Maharashtra Rs.7,88,17,880/-, Cash deposit ... make any compliance resulting into the passing of the best Judgment assessment by the Assessing Officer making addition u/s.69A of the Act for unexplained money at ₹8,38,85,410. We further observe that aggrieved with the addition made by the Assessing Officer assessee preferred appeal before ld.CIT

Jivrajbhai Gopalbhai Kakadia, Surat vs. Ward 1(3)(2), Surat (Present Jurisdiction-Ward 1(3)(1), Surat)

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

ITA 572/SRT/2025[2017-18]Status: DisposedITAT Surat07 Jan 2026AY 2017-18

Bench: Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Shulabh Padshah, C.AFor Respondent: Ms. Jayshree Thakur, Sr. D.R

Section 142(1)Section 143(2)Section 68Section 69A

erred in invoking the provisions of Section 69A of the Act in case of Appellant considering cash deposits of Rs 32,00,000/- as Unexplained Money On facts and circumstances of the case, the provisions of Section 69A of the Act are just not attracted in case of Appellant ... please be held accordingly 3. The Learned CIT (Appeals) has erred in confirming the addition made of Rs 32,00,000/- on account of Unexplained money u/s 69A of Income Tax Act. It is submitted that the necessary details and explanations explaining the source of cash deposits were available with

Saluja Steel and Power Pvt. Ltd., Giridih vs. ACIT, C, Dhanbad

In the result, appeal of the assessee is allowed

ITA 287/RAN/2025[13-14]Status: DisposedITAT Ranchi07 Jan 2026

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Rajib Jain, CIT-DR

Section 131Section 142(1)Section 143(3)Section 148Section 156

income of the Petitioner and whether the addition is sought to be made on account of Cash Credit (Section 68), Unexplained Investments (Section 69), Unexplained Money (Section 69A), Amount of Investment, etc. not fully disclosed in books of account (Section 698), Unexplained Expenditure, etc. (Section 69C). The requirement of each

Akheto Yepthomi, Dimapur vs. Income Tax Officer, Ward-1, Dimapur

In the result, ITA No. 246/GTY/2025 is dismissed

ITA 246/GTY/2025[2021-22]Status: DisposedITAT Guwahati07 Jan 2026AY 2021-22

Bench: Or At The Time Of Hearing Of The Appeal.” 2.1 The Assessee Has Raised The Following Grounds Of Appeal In Ita No. 246/Gty/2025:

For Respondent: Santosh Kumar Karnani, Addl. CIT

Section 10(26)Section 250Section 271BSection 44ASection 69A

assessee could not explain the source of cash deposits, therefore, the entire cash deposits of Rs. 4,27,79,090/- were treated as unexplained money u/s 69A of the Act. He further observed that the assessee required to maintain books of accounts as per section 44AA

Akheto Yepthomi, Dimapur vs. Income Tax Officer, Ward 1, Dimapur

In the result, ITA No. 246/GTY/2025 is dismissed

ITA 245/GTY/2025[2021-22]Status: DisposedITAT Guwahati07 Jan 2026AY 2021-22

Bench: Or At The Time Of Hearing Of The Appeal.” 2.1 The Assessee Has Raised The Following Grounds Of Appeal In Ita No. 246/Gty/2025:

For Respondent: Santosh Kumar Karnani, Addl. CIT

Section 10(26)Section 250Section 271BSection 44ASection 69A

Arvind Kumar Rungta, Bhagalpur vs. The Income Tax Officer Ward 1(1), Bhagalpur, Bihar

In the result, the appeal of the assessee is allowed

ITA 124/PAT/2025[2017-18]Status: DisposedITAT Patna07 Jan 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri Deepak Kumar, ARFor Respondent: Shri Ashwani Kr. Singal, DR

Section 69A

addition of %8 lacs by the Id. CIT (A) as made by the Id. AO u/s 69A of the Act on account of unexplained money. 3.1. The facts in brief are that the assessee filed the return of income on 02.05.2017, declaring total income of %2,61,800/-. The assessee ... demonetisation, Rs.2,00,000/-of such deposits is considered as explained and balance of Rs.8,00,000/- are treated as unexplained money and brought to tax u/s.69A of the Act. The appellant gets relief of Rs.2,00,000/-. Ground no.1 is partly allowed.” 3.3. After hearing the rival contentions

Nityanand, Sant Kabir Nagar vs. Income Tax Officer, Basti

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 470/LKW/2025[2016-17]Status: DisposedITAT Lucknow07 Jan 2026AY 2016-17

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2016-17 Nityanand V. The Income Tax Officer Vill. & Post Dhamaicha Basti Sant Kabir Nagar (U.P) Tan/Pan:Agzpn3158R (Applicant) (Respondent) Applicant By: Shri Vikram Acharya, Aca Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 06.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2016-17. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Teacher Employed With The Government Of U.P. & Earned Salary Income. The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits To The Tune Of Rs.2,16,55,000/- In His Bank Account No.144200101001330 Maintained With Corporation Bank During The Year Under Consideration & The Cash Deposited By The Assessee During The Demonetization Period, I.E. From 01.04.2015 To 31.302.016 Was Rs.15,05,000/-. The Assessing Officer (Ao)

For Respondent: Shri R.R.N. Shukla, D.R

Section 115BSection 142(1)Section 143(3)Section 144Section 147Section 148Section 69A

explanation/evidence /source for cash deposits of Rs.15,05,000/- in the bank account maintained with Corporation Bank, the same was to be treated as unexplained money of the assessee under section 69A of the Act. The AO completed the assessment under section 143(3) read with 147 and 144B

Late Madan Lal Gupta Through Legal Heir Abhishek Gupta, Barabanki vs. ITO Ward 5(4), Barabanki-1, Barabanki

In the result, the appeal of the assessee stands allowed

ITA 437/LKW/2025[2017-18]Status: DisposedITAT Lucknow07 Jan 2026AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Late Madan Lal Gupta V. Ito Through Legal Heir Ward 5(4) Abhishek Gupta Barabanki - 1 367, Qanoon Goyan Nawabganj, Barabanki U.P) Tan/Pan:Acepg5468Q (Applicant) (Respondent) Applicant By: Shri Gaurav Gupta, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Retired Assistant Engineer In The U.P. Power Corporation, Drawing Pension. The Assessee E-Filed His Return Of Income For The Year Under Consideration On 27.07.2017 Declaring A Total Income Of Rs.4,78,310/- After Claiming A Deduction Under Chapter Vi-A, Amounting To Rs.1,50,000/-. The Case Of The Assessee Was Selected For Limited Scrutiny Under The Computer Aided Scrutiny Selection (Cass) For The Reason Of ‘Cash Deposit During The Demonetization Period’. Accordingly, A Notice Under Section 143(2) Of The Income Tax Act, 1961 (Hereinafter Called

For Respondent: Shri R.R.N. Shukla, D.R

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 69A

assessing the total income of the assessee at Rs.17,69,810/- after making an addition of Rs.12,91,500/- as unexplained money under section 69A of the Act. 2.1 The AO also invoked the provisions of section 115BBE of the Act and initiated penalty proceedings under sections 271AAC and 272A

Deepti Social Service Society, Hindupur vs. ITO., Exemption Ward, Tirupati

ITA 920/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Jan 2026AY 2018-19

Bench: Us:

Section 147Section 234ASection 69A

aforesaid show cause notice (SCN), dated 15/09/2023, the AO was constrained to treat the entire amount of Rs. 1,24,91,245/- as the unexplained money of the assessee society under section 69A of the Act. Accordingly, the AO, vide his order under section 147 r.w.s 144 r.w.s 144B

Mrl Trading Company, Hyderabad vs. ITO., Ward-7(1), Hyderabad

ITA 29/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.29/Hyd/2025

For Appellant: CA A SrinivasFor Respondent: MS Kritika Jaiswal, Sr. AR

Section 143(3)Section 69A

provisions of section 69A of the Act against the undisputed factual position discussed above. Section 69A of the Act reads as under: "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 and such

Balguri Rajeshwar Rao, Hyderabad vs. ITO, Ward- 11(1), Hyderabad

ITA 1728/HYD/2025[2016-17]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1728/Hyd/2025

For Appellant: T Chaitanya Kumar, AdvocateFor Respondent: Helen Ruby Jesindha, Sr. AR

Section 133(6)Section 142(1)Section 147Section 148Section 148ASection 250Section 69A

confirming the action of the Assessing Officer in making an addition of Rs.1,18,92,850/ u/s 69A of the Act towards alleged unexplained money without properly appreciating the nature of the transactions and the explanations submitted by the assessee. 5. That the authorities below failed to appreciate that ... cause notices dated 20.12.2023 and 29.01.2024. Since the assessee did not comply with the notices, the Assessing Officer has made addition on account of unexplained money towards variations amounting to Rs.1,18,92,850/-u/sec.69A r.w.s.115BBE of the Income Tax Act, 1961 vide order dated 14.02.2024 passed u/sec.147 r.w.s.144 r.w.s.144B

Atchutha Venkata Sreenivas Rao, Rangareddy vs. ACIT., Central Circle-2(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1414/HYD/2025[2020-21]Status: DisposedITAT Hyderabad07 Jan 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1414/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Atchutha Venkata Vs. Assistant Commissioner Sreenivasa Rao, Of Income Tax Ranga Reddy Central Circle 2(1) Pan:Adgpa1171P Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Praveen Kumar राज" व "ारा/Revenue By:: Smt. Helen Ruby Jesindha, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Atchutha Venkata Sreenivasa Rao (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) Dated 18.07.2025 For The A.Y 2020-21. Page 1 Of 7

For Appellant: CA Praveen KumarFor Respondent: : Smt. Helen Ruby Jesindha

Section 132Section 142(1)Section 143(2)Section 153CSection 69A

alleged cash receipt. Not being satisfied with the explanation furnished by the assessee, the Ld. AO treated the amount of Rs.1,83,600/- as unexplained money under section 69A of the Act and added the same to the total income of the assessee. Page

Thalla Srisailam Goud, Ibrahimpatnam vs. Income Tax Officer, Ward 9(1), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 589/HYD/2024[2013-14]Status: DisposedITAT Hyderabad07 Jan 2026AY 2013-14

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Respondent: Ms. U. Mini Chandran, CIT-DR and Ms. Payal Gupta, SR-DR

Section 147Section 148

addition made by the AO amounting to ₹13,56,61,747/- treating cash deposits made in the bank account of the appellant as unexplained money even though it was explained that the entire amount represents turnover of the appellant from, which was evident from its audited books of accounts ... documentary evidence is placed on record. 11.The NFAC erred in confirming the addition of the AO wherein the cash deposits are treated as Unexplained money u/s 69A even though the appellant has produced audited books of accounts and explained the cash deposits to form part of its turnover

Desu Enterprises, Ongole vs. ITO., Ward-1, Ongole

In the result, the appeal of the assessee in ITA No

ITA 549/HYD/2024[2015-16]Status: DisposedITAT Hyderabad07 Jan 2026AY 2015-16

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.549 & 589/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 & 2013-14) 1. M/S. Desu Enterprises, Ongole (A.P.) Pan: Aagfd1940C 2. Thalla Srisailam Goud, Ibrahimpatnam. Pan: Αιτpg3044K (Appellants) Vs. Income Tax Officer, Ward-1, Ongole. Income Tax Officer, Ward 9(1), Hyderabad. (Respondents) निर्धारिती द्वारा / Assessees By: राजस्व द्वारा / Revenue By: Shri Sashank Dundu, Advocate Ms. U. Mini Chandran, Cit-Dr & Ms. Payal Gupta, Sr-Dr सुनवाई की तारीख / Date Of Hearing: 06/11/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Appeals Are Filed By M/S. Desu Enterprises & Shri Thalla Srisailam Goud (“The Assessees”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 26.02.2024 & 09.04.2024 For The A.Ys. 2015-16 & 2013-14 Respectively. Since The Issues Involved In These Two Appeals Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Respondent: Shri Sashank Dundu, Advocate

Section 147Section 148

Adhimoolam Varadham Murugan, Tiruvallur vs. ITO, Ncw-5(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 2755/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Jan 2026AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2755/Chny/2025 िनधा%रण वष% /Assessment Year: 2015-16

For Appellant: Mr. H.Yeshwanth Kumar, C.A *+For Respondent: Ms. Latchana, CIT

Section 147Section 148Section 148ASection 250Section 69A

notices issued by the A.O, the A.O completed the assessment u/s. 147 r.w.s 144 of the Act, treating the entire cash deposit as unexplained money u/s.69A of the Act. Aggrieved, the assessee filed further appeal before the CIT(A). The CIT(A) dismissed the appeal ex-parte for the reason

Tamilnadu State Apex Fisheries Coop Federation Ltd., Chennai vs. ITO, Ncw-19(1), Chennai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2753/CHNY/2025[2016-17]Status: DisposedITAT Chennai07 Jan 2026AY 2016-17

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2750, 2751, 2752 & 2753/Chny/2025 िनधा%रण वष% /Assessment Years: 2013-14, 2014-15 & 2016-17

For Appellant: Mr. M. Ravi Kumar, AdvocateFor Respondent: Ms. Latchana, JCIT

Section 147Section 148Section 250Section 271(1)(c)Section 69A

report explaining the source for cash deposit. The A.O did not accept the submissions of the assessee and treated the cash deposit as unexplained money u/s. 69A of the Act. Aggrieved, the assessee filed further appeal before the CIT(A). 3. There was a delay in filing the appeal before

Tamilnadu State Apex Fisheries Coop Federation Ltd., Chennai vs. ITO, Ncw-19(1), Chennai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2752/CHNY/2025[2014-15]Status: DisposedITAT Chennai07 Jan 2026AY 2014-15

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2750, 2751, 2752 & 2753/Chny/2025 िनधा%रण वष% /Assessment Years: 2013-14, 2014-15 & 2016-17

For Appellant: Mr. M. Ravi Kumar, AdvocateFor Respondent: Ms. Latchana, JCIT

Section 147Section 148Section 250Section 271(1)(c)Section 69A

Tamilnadu State Apex Fisheries Coop Federation Ltd., Chennai vs. ITO, Ncw-19(1), Chennai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2751/CHNY/2025[2014-15]Status: DisposedITAT Chennai07 Jan 2026AY 2014-15

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2750, 2751, 2752 & 2753/Chny/2025 िनधा%रण वष% /Assessment Years: 2013-14, 2014-15 & 2016-17

For Appellant: Mr. M. Ravi Kumar, AdvocateFor Respondent: Ms. Latchana, JCIT

Section 147Section 148Section 250Section 271(1)(c)Section 69A

Tamilnadu State Apex Fisheries Coop Federation Ltd., Chennai vs. ITO, Ncw-19(1), Chennai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2750/CHNY/2025[2013-14]Status: DisposedITAT Chennai07 Jan 2026AY 2013-14

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2750, 2751, 2752 & 2753/Chny/2025 िनधा%रण वष% /Assessment Years: 2013-14, 2014-15 & 2016-17

For Appellant: Mr. M. Ravi Kumar, AdvocateFor Respondent: Ms. Latchana, JCIT

Section 147Section 148Section 250Section 271(1)(c)Section 69A