“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

Income Tax Officer, Delhi vs. Himanshu Goel, Mayur Vihar Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 5232/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68Section 69A

sales of goods, properly recorded in the books and offered for taxation, cannot be treated as unexplained cash credits u/s 68 (and by extension, unexplained money u/s 69A) as this would result in double taxation. The Tribunal in Haripanna Jewellers emphasized that if the assessee's books, sales, purchases

DCIT, Delhi vs. Jmk Jewels Private Limited, Delhi

ITA 4282/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

failed to appreciate that cash sales since have already been offered as income by the appellant could not presumptively be rejected and held as unexplained money so as to tax the same under section 68 of the Act, when the section 68 of the Act itself is wholly inapplicable

Jmk Jewels Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Delhi

ITA 3609/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Section 115BSection 143(3)Section 44ASection 68

Klj Developers (P) Ltd., Delhi vs. DCIT, Circle-31, Delhi

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

ITA 6027/DEL/2024[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2014-15 M/S. Kjl Developers (P) Ltd., Vs. Deputy Commissioner Of Kjl House, 8A, Shivaji Marg, Income, Central Circle-31, Najafgarh Road, Karam Pura New Delhi South West, Delhi- 1100 15 Pan No. Aacck7445E (Appellant) (Respondent)

For Appellant: Shri Ankit Kumar, AdvsFor Respondent: Shri Dayainder Singh, CIT DR

Section 139(1)Section 139(5)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 250

Appeals) has also erred both in law and on facts in upholding an 6 addition of Rs. 4,65,00,000/-representing the alleged unexplained money on the basis of following loose sheets seized from premises of Sh. Harjeet Singh and brought to tax u/s 69A of the Act. Sr.No

Income Tax Officer(E) Ward- 2(4), New Delhi, Civic Centre New Delhi vs. Prakash Sewa Trust, Paschim Vihar

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

Order the assessing authority has simply made additions in the returned income without stating whether it is a case of cash credit, unexplained investments, unexplained money, amount of investment, etc. not fully disclosed in books of account, unexplained expenditure, etc. The impugned Order is therefore without authority ... 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 69B), Unexplained Expenditure, etc. (Section 69C). The requirement of each

Income Tax Officer, Civic Centre, New Delhi vs. Naveen Arora, Lajpat Nagar, Delhi

Appeal is partly allowed

ITA 3251/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla

Section 144Section 172Section 195Section 69ASection 69C

passed by the Assessing Officer on 17.12.2018. In such order two additions were made by the Assessing Officer. The first being addition u/s.69A of unexplained money for Rs.26,52,500/-, which was deposited by the assessee in its bank accounts with HDFC bank and ICICI bank respectively during the demonetization

Neetal Relan, New Delhi vs. ACIT, Central Circle-14, New Delhi

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

ITA 3038/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 153CSection 250

been made on account of unexplained expenditure while in the body of order at para no. 7.14 the same has been held as unexplained money in the hands of the assessee added and confirmed by the CIT(A) Under Section 69A. The CIT(A) is not sure as to whether

Neetal Relan, New Delhi vs. ACIT, Central Circle-14, New Delhi

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

ITA 3037/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 153CSection 250

Assistant Commissioner of Income Tax, Central Circle-2, Surat vs. Manoj Chhitubhai Patel, Surat

In the result, the appeal filed by the revenue stands dismissed

ITA 507/SRT/2025[2018-19]Status: DisposedITAT Surat06 Jan 2026AY 2018-19

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 132Section 250Section 69A

appreciating the incriminating nature of evidences & facts detailed by the AO relating to the protective addition of Rs. 3,27,350/- being unexplained money (5000 US Dollars) of the Assessee found in course of the Search Action. 3. On the facts and in the circumstances of the case ... making addition of Rs.416745000/- on account of unaccounted investment and addition of Rs.3,27,350/- u/s 69A of the Act on account of unexplained money, both the additions have been made on protective basis. According to the AO, a search action u/s 132 of the Act was carried

Assistant Commissioner of Income Tax, Central Circle-2, Surat vs. Manoj Chhitubhai Patel, Surat

In the result, the appeal filed by the revenue stands dismissed

ITA 506/SRT/2025[2017-18]Status: DisposedITAT Surat06 Jan 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 132Section 250Section 69A

Income Tax Officer, Ranchi, Jharkhand vs. Amba Carbonisation Pvt. Ltd., Ranchi, Jharkhand

In the result, the appeal of the revenue is dismissed

ITA 61/RAN/2024[2013-14]Status: DisposedITAT Ranchi06 Jan 2026AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 250Section 270ASection 273B

with section 144B of the Act, making an addition of ₹13,64,83,677/- under section 69A of the Act, treating the same as unexplained money. A perusal of the assessment records reveals that two notices under section 148 of the Act dated 16.03.2021 and I.T.A. No.61/Ran/2024 Amba Carbonisation

M/S Anjeneya Ispat Ltd., Saraikela vs. Deputy Commissione of Income Tax, Circele-1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 75/RAN/2022[2009-10]Status: DisposedITAT Ranchi06 Jan 2026AY 2009-10

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.75/Ran/2022 Assessment Year: 2009-10 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand- 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Cit(A)”) Dated 25.09.2017 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2019–20 Declaring A Total Income Of ₹62,64,116. The Case Was Selected For Complete Scrutiny. During The Relevant Previous Year, A Survey Operation Under Section 133A Of The Income-Tax Act, 1961 Was Conducted At The Business Premises Of The Assessee On 16.02.2019. Subsequently, Statutory Notices Under Sections 143(2) & 142(1) Of The Act Were Issued. In Response Thereto, The Assessee Appeared From Time To Time & Furnished Various Details & Documents As Called For. The Same Were Examined & Discussed By The Assessing Officer During The Course Of Assessment Proceedings. During

Section 10(23)Section 133ASection 133A(3)Section 145ASection 14ASection 250Section 40Section 69Section 69C

provisions of section 68 are not applicable to the appellant". Therefore, the ld. CIT(A) treated the addition of Rs. 6,00,000/- as unexplained money under section 69A of the Act and confirmed the addition. Section 68 of the Act deals with "unexplained Credit" in the books ... assessee and section 69A of the Act deals with "unexplained money, bullion, jewellery or other valuable article". Both are entirely different. Though the Assessing Officer has not mentioned the section 68 of the At in his order, the very fact that he calls it "unexplained credit" and not "unexplained money

Chaman Lal, Mandi vs. Income Tax Officer, Mandi

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

ITA 489/CHANDI/2025[2017-2018]Status: DisposedITAT Chandigarh06 Jan 2026AY 2017-2018

Bench: the National Faceless Appeals Centre-Commissioner of Income tax (Appeals) and the appeal is dismissed and stated that in the absence of any document/ evidence, no separate reasons needs to be recorded by the appellate authority for affirming the order of A.O. and decided that "It is evident that the appellant during the assessment as well as appellate proceedings failed to furnish documentary evidences/ proper explanation in support of his contention, so in view of aforesaid facts hence the

For Appellant: Shri Rohit Kumar, ITPFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 139(1)Section 142(1)Section 147Section 148Section 44ASection 69A

deposits, the AO completed the assessment under section 144 of the Act. The entire cash deposits of Rs.1,77,13,895/- were treated as unexplained money under section 69A read with section 115BBE and added to the total income. Accordingly, the total income was assessed at Rs.1 ... noted that the sole issue for consideration was the addition of Rs.1,77,13,895/- as unexplained money under section 69A of the Act. The assessee claimed that the cash deposits represented sale proceeds from a fruit and vegetable business carried on in the names of “Chaman Lal Avinashi Fruit

Shah Petroleum Products, Chembur vs. ACIT, Circle 27(3), Mumbai, Vashi

In the result, appeal filed by the Assessee stands allowed

ITA 4905/MUM/2025[2012-13]Status: DisposedITAT Mumbai06 Jan 2026AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2012-13 Shah Petroleum Products, Acit, Circle 27(3), Bpcl Petrol Pump, Opp. Room No. 423, 4Th Floor, Shoppers Stop, Ghatkopar Vs. Tower No. 6, Vashi Railway Mahul Road, Chembur, Mumbai, Station Commercial Mumbai – 400089. Complex, Vashi, Pan – Aabfs2738Q Navi Mumbai – 400703. (Appellant) (Respondent) Present For: Assessee By : Shri Subodh Ratnaparkhi, Ld. A.R. Revenue By : Ms. Kavitha Kaushik, Sr. D.R. Date Of Hearing : 06.11.2025 Date Of Pronouncement : 06.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.06.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2012-13. 2. In This Case, The Ao Had Received The Information Dated 19.03.2019 From The Ddit (Inv.) Unit – 5(4), Mumbai To The Effect That In A Survey Action Under Section 132 Of The Act Carried Out In The Case Of M/S. Evergreen Enterprise, Statement Of Mr. Nilesh Bharani, Being Partner Of Such Enterprises Recorded Under Section 132 (4) Of The Act, Wherefrom Undisclosed Activity Of Money 2 Shah Petroleum Products

For Appellant: Shri Subodh Ratnaparkhi, Ld. A.RFor Respondent: Ms. Kavitha Kaushik, SR. D.R

Section 132Section 147Section 148Section 250

been handled above by the AO. The appellant has not provided the AO with material fit enough not to treat the cash loan as unexplained money. He has not provided me with enough substance either. In such circumstances, I find no reason to interfere with the order

Neptune Fincot Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax, Circle 15(1)(2), Mumbai

In the result, the assessee succeeded ground no

ITA 3946/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 144BSection 147Section 148Section 254(1)Section 69A

erred in confirming the addition of Rs.77,32,714/- made by the Ld. AO u/s.69A of the Act on account of alleged unexplained money. The Ld. CIT(A) failed to appreciate, and ought to have held, that - (a) there was no evidence or material on record for the transactions

Income Tax Officer, Ward - 2 (1), Varanasi vs. Prominent Datamatics Marketing Pvt. Ltd., Varanasi

ITA 135/VNS/2020[2017-2018]Status: DisposedITAT Varanasi05 Jan 2026AY 2017-2018

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 124(1)(a)Section 124(2)Section 124(3)(a)Section 250(1)Section 255(4)Section 69A

difference amount of Rs 2.64,90,092/- (Rs 2,73,59,647/- minus Rs 8,69,555/-) shall not be treated as unexplained money u/s 69A of the Act and brought to tax u/s 115BBE of IT Act, 1961 which attracts the tax @60% plus surcharge @25% on such ... difference amount of Rs 2,64,90,092/- (Rs.2,73,59,647/- minus Rs. 8,69,555/-) shall not be treated as unexplained money u/s 69A of the Act and brought to tax u/s 115BBE of I.T. Act. 1961 which attracts the tax @60% plus surcharge @25% an such

Chand Jewellers, Nakodar vs. Income Tax Officer, Jalandhar

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

ITA 574/ASR/2025[2017-18]Status: DisposedITAT Amritsar05 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 574/Asr/2025 Assessment Year: 2017-18 Chand Jewellers, Bazar Sarafan Vs. Ito-Ward Nakodar, Distt. Jalandhar. Jalandhar. [Pan:-Aahfc5908J] (Appellant) (Respondent) Appellant By Sh. Amit Bajaj, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 115BSection 147Section 148Section 250Section 69A

taxed as business income, and on the other hand, the corresponding cash deposits in the bank arising from such sales are simultaneously treated as unexplained money, which results in double taxation and is contrary to law, logic, and settled judicial principles. 8. That the impugned addition is not backed

Nayna Mukeshkumar Kotecha, Dar Es Salaam, Tanzania vs. ACIT, International Taxation, Rajkot

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

ITA 187/RJT/2024[2015-16]Status: DisposedITAT Rajkot05 Jan 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Sumit Shingala, Ld. A.RFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 147Section 148Section 148ASection 69A

explanation of the assessee is not satisfactory and the money held in form of cash deposited into bank deposits are held as unexplained money and are deemed income for the financial year in which the investments in form of money ownership are made. The unexplained investments are deemed income

Sanoj Kumar Singh, Hajipur vs. ITO, Ward-1(3), Vaishali

The appeal of the revenue stands dismissed

ITA 366/PAT/2025[2017-18]Status: DisposedITAT Patna05 Jan 2026AY 2017-18

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI RAJESH KUMAR (Accountant Member)

Section 143(2)Section 250Section 68

demonetization period which has been treated as deemed income of the assessee and added to the total income u/s. 69A of the Act as unexplained money. We find that written submissions and all the relevant documentary evidences were placed on record. 7.1 The foremost point which invites our attention ... other material except for the estimation of probable sales value done by the Ld. AO for the purpose of treating the deemed income as unexplained money in the hands of the assessee. We also note that assessee has duly recorded in its books of accounts all the sales made

Virendra Vijaysingh Pardeshi, Nashik vs. Income Tax Office Ward 2(1) Nashik, Nashik

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

ITA 2620/PUN/2025[2020-21]Status: DisposedITAT Pune05 Jan 2026AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2620/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Virendra Vijaysingh Vs. Ito, Ward-2(1), Nashik. Pardeshi, Row House No.10, Swapnpurti Cooperative Housing Society, Kalptaru Nagar, Nashik- 422006. Pan : Anhpp9809L Appellant Respondent Assessee By : Shri Rakesh Pardeshi Revenue By : Shri Ganesh B. Budruk Date Of Hearing : 18.12.2025 Date Of Pronouncement : 05.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.09.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Learned Cit-Appeals Erred In Upholding The Addition Of Rs.2500000 Made By The Assessing Officer U/S 69A Of The Income-Tax Act, 1961, Merely For Non-Appearance Relying Solely On Procedural Default & Ignoring That Appellate Proceedings Are Continuation Of Assessment & Must Be Decided On Merits Based On Record & Written Submissions Already Filed.

For Appellant: Shri Rakesh PardeshiFor Respondent: Shri Ganesh B. Budruk

Section 139(4)Section 143(2)Section 147Section 148Section 250(6)Section 271DSection 68Section 69A

without corroboration. The addition is unsustainable in law as the Department failed to prove the Appellant's actual possession or discovery of the alleged unexplained money. 3. On the facts and in the circumstances of the case and in law Principles of natural justice were violated as cross-examination ... same seized materials, instead treating the alleged receipt as a cash loan (proposing penalty u/s 271D) The present addition of repayment as "unexplained money" is therefore contradictory and inconsistent with the Department's own earlier stand. 6. The learned CIT-Appeals failed to appreciate that the Department never discharged