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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

Rahul Aggarwal, India vs. Income Tax Officer Ward 30(3), Civic Centre, Delhi

In the result, the appeal filed by the assesse is allowed

ITA 6053/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarrahul Aggarwal, Income Tax Officer, 7708 (77 Avenue), Ward-30(3), Second Floor, Dlf Phase-Iv, Vs. Delhi. Gurugram-122009, Haryana. Pan-Ahcpa7394J (Appellant) (Respondent) Assessee By Shri Rajesh Mahna, Adv. & Shri Narender Goel, Adv. Shri Manish Gupta, Sr. Dr Department By Date Of Hearing 09.03.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: This Appeal Filed By The Assessee Is Against Order Dated 08.08.2025 Of Learned Commissioner Of Income Tax (Appeals)-3, Chennai [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 10.12.2019 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Filed Return Of Income On 17.03.2018 Declaring Total Income Of Rs.4,08,280/- Which Was Processed By The Cpc U/S 143(1) Of The Income Tax Act, 1961. Subsequently, The Case Was Selected For Limited Scrutiny Through Cass-2018Cycle On The Reason Of “Credit Card Payments”. Rahul Aggarwal Vs. Ito

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

circumstances of the case and in law, the Ld. CIT(A) erred in treating the Appellant's own capital and disclosed funds as unexplained money under section 69A. The gifts from relatives credited in the capital account (as acknowledged in para 7.13 of the CIT(A)'s order) and withdrawals

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1594/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

deleted. Aggrieved, the revenue is in further appeal before us. 3.8 On the issue of cash found for Rs.103.81 Lacs which was treated as unexplained money u/s 69A, the assessee contended that this cash represent proceeds of unrecorded jewellery sales which had already led to shortage of stock and since

Sukhdev Singh Grewal, Ludhiana vs. ITO Ward 6(1), Income Tax Department Ludhiana

The appeal stand allowed

ITA 1308/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh12 Mar 2026AY 2011-12

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.1308/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2011-12) Shri Sukhdev Singh Grewal Ito Ward – 6(1) बनाम/ Vs. 66-F, Shaheed Bhagat Singh Nagar Aaykar Bhawan, Rishi Nagar Ludhiana, Punjab - 141013 Ludhiana (Punjab) - 141001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abepg-0070-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. I.S. Khurana (Ca) –Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10-03-2026 घोषणाकीतारीख /Date Of Pronouncement 11-03-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2011-12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 19-08-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 144 R.W.S 147 Of The Act On 28-03-2025. Having Heard Rival Submissions, The Appeal Is Disposed-Off As Under. 2. Initially, The Case Of The Assessee Was Reopened & An Assessment Was Framed Against The Assessee On 26-12-2018 Making

For Appellant: Sh. I.S. Khurana (CA) –Ld. AR (Virtual)For Respondent: Sh. Dr Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 144Section 69A

source of Rs.2 Lacs was also accepted. However, the remaining deposit of Rs.5,29,500/- were added by Ld. AO as unexplained money u/s 69A though the assessee stated that the same was sourced out of earlier cash withdrawals and agricultural rental income. The Ld. CIT(A) confirmed the addition

Saraf the Jeweller, Chandigarh vs. The DCIT/ACIT Central Circle- 2, Chandigarh

Appeal stand dismissed

ITA 1232/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

deleted. Aggrieved, the revenue is in further appeal before us. 3.8 On the issue of cash found for Rs.103.81 Lacs which was treated as unexplained money u/s 69A, the assessee contended that this cash represent proceeds of unrecorded jewellery sales which had already led to shortage of stock and since

Shivani Gupta, Delhi vs. Ward 70(1), New Delhi

In the result, the assessee gets further relief of Rs

ITA 7074/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Mar 2026AY 2017-18

Bench: Shri Vikas Awasthyआअसं.7074/धिल्ली/2025 (नि.व. 2017-18) Shivani Gupta, 50, Second Floor, Vigyan Vihar, Delhi 110092 ...... अपीलार्थी/Appellant Pan: Afmpg-9292-B बिाम Vs. Ward-70(1), R. No. 1009, E-2, Civic Centre, ..... प्रनिवादी/Respondent New Delhi 110002 अपीलार्थी द्वारा/Appellant By : Shri V. Raj Kumar, Advocate प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 12/03/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Additional/Joint Commissioner Of Income-Tax (Appeals)-4, Chennai (Hereinafter Referred To As ‘The Cit (A)’) Dated 10.09.2025, For The Assessment Year 2017-18. 2. The Appeal Is Time Barred By 3 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons Causing Delay In Filing Of Appeal. After Perusal Of The Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, The Delay Has Been Caused For The Reasons Stated In Petition Which Appears To Be Bonafide. Thus, Delay In Filing Of Appeal Is Condoned & Appeal Is Admitted For Decision On Merits.

For Appellant: Shri V. Raj Kumar, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115BSection 69A

after considering submissions of the assessee allowed relief of Rs.2,00,000/- and made addition of remaining amount of Rs.9,79,500/- as unexplained money u/s 69A r.w.s. 115BBE of the Act. The assessee carried the issue in appeal before the CIT(A), but remained unsuccessful. Hence, the present appeal