“ unexplained money ”

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

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.

342 ITR 169 · 2012 · High Court

658

Kale Khan Mohammad Hanif v. CIT

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.

50 ITR 1 · 1963 · Supreme Court

581

Lalchand Bhagat Ambica Ram v. CIT

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.

37 ITR 288 · 1959 · Supreme Court

570

CIT v. Daulat Ram Rawatmull

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.

87 ITR 349 · 1973 · Supreme Court

525

107 ITR 938 · 1977 · Supreme Court

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

477

CIT v. Precision Finance Pvt. Ltd.

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.

208 ITR 465 · 1994 · High Court

427

172 ITR 250 · 1988 · Supreme Court

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

340

ITA 4799/DEL/2024[2017-18]Status: DisposedITAT Delhi19 Dec 2025AY 2017-18

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

ACIT, New Delhi vs. Pawan Kumar Bansal, Delhi

In the result, Appeal of the Revenue in ITA

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla

Section 153CSection 153DSection 69A

amount received has been disclosed by him as his income for the year. 27. The provisions of Section 69A are reproduced as under:- "69A. [ Unexplained money, etc. ] "-Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article

Nidhi Rani, Panipat vs. Income Tax Office, Ward-1, Panipat

In the result, appeal of the assessee is allowed

ITA 3323/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] Smt. Nidhi Rani Vs Ito 1361, Sector-25, Part-Ii Ward-1, Panipat, Haryana-132103 Panipat Pan-Arrpr9400P Appellant Respondent Appellant By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. & Shri Saksham Agarwal, Ca Respondent By Shri Shyam Manohar Singh, Sr.Dr Date Of Hearing 24.09.2025 Date Of Pronouncement 19.12.2025 Order

Section 142(1)Section 143Section 143(2)Section 143(3)Section 234ASection 250Section 68

filed enquiry was made by deputing ward inspector and made the addition of unsecured loan received by holding the same as unexplained money. For this, he placed reliance on the judgment of Hon’ble Supreme Court in the case of Orissa Corporation reported

Bhoj Raj, Agra vs. Ward 1(1)(1), Agra

In the result, appeal filed by the assessee is allowed

ITA 436/AGR/2025[2017-2018]Status: DisposedITAT Agra18 Dec 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18

Section 142(1)Section 143(3)Section 147Section 148Section 151Section 69A

present case, the Revenue has treated the cash deposited by the assessee during the demonetisation period in its bank account as an unexplained money and added the same to the total income of the assessee under section 69A of the Act. It is the plea of the assessee that

Anil Kumar Mandal, Fatehpur, Sahibganj vs. ITO, Sahibganj

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

ITA 461/RAN/2024[2016-17]Status: DisposedITAT Ranchi18 Dec 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.461/Ran/2024 Assessment Year: 2016-17 Anil Kumar Mandal.. …………….…….…............................……….……Appellant Fathepur, Balapokhar Rajmahal, Jharkhand-816109. [Pan: Bkhpm1302H] Vs. Ito, Sahibganj……………….....….…..….........……........……...…..…..Respondent Appearances By: Shri R R Mittal, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 23.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That, Based On Information Available With The Assessing Officer, It Was Found That The Assessee Had Deposited Cash Amounting To ₹44,73,800 In A Savings Bank Account During The Relevant Assessment Year. On Account Of Such Cash Deposits, The Case Of The Assessee Was Reopened Under Section 147 Of The Income-Tax Act, 1961 After Recording Reasons & Obtaining The Necessary Approval From The Competent Authority. Consequently, Notice Under Section 148 Of The Act Was Issued To The Assessee For Filing The Return Of Income. However, The Assessee Did Not File The Return Of Income Nor Complied With The Notices Issued Under Section 142(1) Of The Act. In The Absence Of Any Compliance, The Assessing Officer Completed The Assessment Ex Parte & Treated The Entire Cash Deposit Of ₹44,73,800 In The Savings Bank Account As

Section 142(1)Section 147Section 148Section 250Section 69A

assessment ex parte and treated the entire cash deposit of ₹44,73,800 in the savings bank account as I.T.A. No.461/Ran/2024 Anil Kumar Mandal unexplained money and added the same to the total income of the assessee under section 69A of the Act. 3. Aggrieved, the assessee preferred an appeal

Baldev Singh S/O Sh. Jodha Singh, Dhuri vs. ITO, Ward (1), Malerkotla

In the result, appeal of the assessee is allowed

ITA 498/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh18 Dec 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 498/Chd/2025 िनधा"रण वष" / Assessment Year : 2016-17 Shri Baldev Singh, Vs The Ito, S/O Shri Jodha Singh, Ward-1, Village-Ghanaur Kalan, Malerkotla. Po-Ghanaur Khurd, Dhuri. "ायी लेखा सं./Pan No: Efxps1227B अपीलाथ"/Appellant ""थ"/Respondent Assessee By : Shri Mandeep Singh Narike, Advocate Revenue By : Shri Vivek Vardhan, Addl.Cit Sr. Dr Date Of Hearing : 17.12.2025 Date Of Pronouncement : 18.12.2025

For Appellant: Shri Mandeep Singh Narike, AdvocateFor Respondent: Shri Vivek Vardhan, Addl.CIT Sr. DR

Section 144Section 69A

these grounds No.3 & 4, the appellant has challenged the addition of u/s. 69A of an amount of Rs.1,96,70,500/- as unexplained money u/s. 69A being the cash deposited by the appellant in his Axis Bank account during the AY 2016-17. In this case, the assessing officer ... made an addition u/s. 69A of an amount of Rs.1,96,70,500/- as unexplained money u/s. 69A being the cash deposited by the appellant in his Axis Bank account during the AY 2016-17. In this regard, the appellant had submitted additional evidences viz., sale deed document, affidavit from

Pradeep Janardhan Sakhare, Sambhajinagar vs. ITO, Ward-1(A), Aurangabad

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

ITA 2509/PUN/2025[2018-19]Status: DisposedITAT Pune18 Dec 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2509/Pun/2025 धििाारण वर्ा / Assessment Year : 2018-19 Pradeep Janardhan Sakhare, Ito, Ward – 1(1), Ashay Regency, Flat No. 9, Aurangabad New Vishal Nagar, Chh. Sambhajinagar, Vs. Maharashtra-431001 Pan : Bobps8283M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi (Virtual) Department By : Smt. Indira R. Adakil Date Of Hearing : 04-12-2025 Date Of 18-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 26.09.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2018-19. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. For Ay 2018-19, The Assessee Filed His Return Of Income Declaring Income Of Rs.3,17,830/-. Based On The Information Received From The Insight Portal Under „High Risk Criu/Vru Information‟, It Was Found That The Assessee Has Done Transaction In Crypto Currency Of Rs.38,54,500/-, The Source Of Which Requires Verification & Also There Were Unexplained Credit Entries Aggregating To Rs.40,44,044/-. As The Assessee Failed To Disclose The Above Transaction In The Itr Filed For The Ay 2018-19, The Ld. Assessing Officer (“Ao”) Had Reason To Believe That The Above Income In Ay 2018-19 Has Escaped Assessment. Accordingly, The Case Of The Assessee Was Reopened U/S 147 By Issue Of Notice U/S 148 Of The Income Tax Act, 1961 (The “Act”) Dated 07.04.2022. In Response Thereto, The Assessee Filed His Return Of Income On 09.06.2023. Statutory Notice(S) U/S 142(1) & 144 Were Then Issued To The Assessee. As The Assessee Failed To File Any Compliance

For Appellant: Shri Shubham N. Rathi (Virtual)For Respondent: Smt. Indira R. Adakil

Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 151ASection 69ASection 69B

addition of Rs.38,54,500/- on account of unexplained investments in crypto currency u/s 69B and credit entries of RS.40,44,044/- as unexplained money u/s 69A of the Act, to the returned income of Rs.3,17,830/-. 3. Aggrieved, the assessee filed an appeal before

Sachin Badrinarayan Somani, Pune vs. ITO Ward, Hingoli

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

ITA 2113/PUN/2025[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

For Appellant: Shri Nemin ShahFor Respondent: Shri Ganesh B. Budruk-Addl. CIT

Section 250Section 271(1)(c)Section 274Section 69A

Ground 2, the Learned CIT(A), has erred in maintaining the addition made by the Ld. AO of Rs. 2,32,53,205/-as unexplained money under Section 69A of the Act The Learned CIT(A) failed to consider and ought to have held that out of total cash deposits ... appellant also made some re-deposits from the surplus cash withdrawn earlier. Thus, the cash re- deposited cannot be treated as unexplained money and therefore the said addition to the extent of re-deposits may be deleted. Ground 4-The Appellant craves leave to add, alter, vary, omit, amend

Sachin Badrinarayan Somani, Pune vs. ITO Ward, Hingoli

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

ITA 2112/PUN/2025[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14

For Appellant: Shri Nemin ShahFor Respondent: Shri Ganesh B. Budruk-Addl. CIT

Section 250Section 271(1)(c)Section 274Section 69A

Amar Kumar Agarwal, Kolkata vs. D.C.I.T., CC - 4(3), Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 2007/KOL/2025[2021-2022]Status: DisposedITAT Kolkata18 Dec 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

ITA 1854/KOL/2025[2012-2013]Status: DisposedITAT Kolkata18 Dec 2025AY 2012-2013

rejected the theory of the assessee and accordingly, added the entire unaccounted cash receipts amounting to ₹17,64,58,253/- as undisclosed/unaccounted sales as unexplained money u/s 69A of the Act and added to the income of the assessee for the years commencing from ... details below:- A.Y. Income chargeable u/s Income now shown Unexplained money chargeable to 69A of the Act u/s 69A in the ITR on tax u/s 69A of the Act, now further this score is excluded added back to the total income of the assessee

Burdwan Satgachia Janakalyan Society, Memari, Burdwan vs. I.T.O., Ward - 1(1), Burdwan

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Burdwan Satgachia Janakalyan Ito Ward 1(1) Society, Aaykar Bhawan, Court Satgachia, Memari, Burdwan, Compound, Burdwan, Vs. West Bengal-713422 West Bengal-713101 (Appellant) (Respondent) Pan No. Aaaab8302K Assessee By : Shri Soumitra Choudhury, Ar Revenue By : Shri Ruchika Sharma, Dr Date Of Hearing: 04.12.2025 Date Of Pronouncement: 18.12.2025

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Ruchika Sharma, DR

Section 131Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 271(1)(b)Section 69ASection 80P

assessee aggregating to ₹68,10,000/- comprising ₹ 55,10,000/- cash deposited and 13,00,000/- time deposit during the year as unexplained money thereby making an addition of ₹68,10,000/- made to the income of the assessee without allowing any deduction ... added the entire amount of deposit into the bank account of ₹68,10,000/- as unexplained money u/s 69A of the Act comprising ₹55,10,000/- cash deposited by the assessee over the period of 12 months as well as time deposits made

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1499/KOL/2025[2021-22]Status: DisposedITAT Kolkata18 Dec 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

ITA 1498/KOL/2025[2020-21]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-21

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarawal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

ITA 1497/KOL/2025[2018-19]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-19

Deputy Commssioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

ITA 1496/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

Deputy Commissioner of Income Tax, Central Circle 4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

ITA 1440/KOL/2025[2019-20]Status: DisposedITAT Kolkata18 Dec 2025AY 2019-20

rejected the theory of the assessee and accordingly, added the entire unaccounted cash receipts amounting to 717,64,58,253/- as undisclosed/unaccounted sales as unexplained money u/s 69A of the Act and added to the income of the assessee for the years commencing from ... details below:- AY. Income chargeable u/s | Income now shown Unexplained money chargeable to 69A of the Act u/s 69A in the ITR on tax u/s 69A of the Act, now further this score is excluded added back to the total income of the assessee

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

ITA 1371/KOL/2025[2022-2023]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-2023

Bongaon Co-Operative Credit Society Limited, Bongaon vs. DCIT, Circle 32, Kolkata

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2022-23 Bongaon Cooperative Credit Society Ltd..…………….……….……….……Appellant First Floor, Banerjee Market Jessore Road, Bongaon, Dist: North 24 Parganas, W.B - 743235.. [Pan: Aaaab6325N] Vs. Dcit, Circle-32, Kolkata….…………...…………………….....……...…..…..Respondent Appearances By: S. Ghosh, Ca, Appeared On Behalf Of The Appellant. Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Year Under Consideration On 28.08.2022 Declaring Nil Income After Claiming Deduction U/S 80P Of The Act Of Rs.25,75,431.98/- . The Case Of The Assessee Was Selected For Scrutiny Through Cass. The Assessment Was Completed Vide Order U/S 143(3) R.W.S. 144B Of The Act Dated 15.03.2024 Determining Total Income At Rs.71,81,740/- By Disallowing Deduction U/S 80P Of The Act With Regard To The Interest Income Received From Banks. Bongaon Cooperative Credit Society Ltd 3. Aggrieved By The Said Order, The Assessee Preferred Appeal Before The Ld. Cit(A) Wherein The Appeal Of The Assessee Has Been Dismissed.

Section 143(3)Section 250Section 68Section 80PSection 80P(2)(d)

collections and deposits have been duly recorded in the books of account and hence, there is no reason to treat the same as unexplained money of assessee. The Ld. A.R. further submitted that merely because demonetized notes ceased to be legal tender, it does not mean that the amount collected ... assessee from its members would become unexplained money of the assessee. The Ld. A.R. also submitted that the Reserve Bank of India issued a series of notifications with regard to the deposit of demonetized notes from 8.11.2016 onwards. He submitted that the RBI, vide notification dated 14.11.2016, clarified that District

DCIT, Central Circle-1(4), Kolkata vs. Educo Ventures Pvt Ltd., Kolkata

Appeal is dismissed

ITA 2144/KOL/2024[2015-16]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-16

Bench: the AO.

ITA 2125/KOL/2024[2014-15]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-15

made addition of Rs.6,00,000/- u/s.69C of the Act as unexplained expenditure and Rs.32,70,000/- u/s.69A of the Act as unexplained money stating that incriminating evidence were found in survey relating to these unaccounted cash transactions. The appellant in its submission has stated that

DCIT Central Circle 1(4), Kolkata vs. Educo Ventures Pvt Ltd, Kolkata

Appeal is dismissed

Bench: the AO.

ITA 2025/KOL/2024[2020-2021]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-2021

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

Bench: the AO.

ITA 2024/KOL/2024[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

Bench: the AO.