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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

Manish Gupta, Gurgaon vs. ITO Ward 2(4), Gurgaon

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

ITA 7269/DEL/2025[2012-13]Status: DisposedITAT Delhi16 Dec 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.7269/धिल्ली/2025 (नि.व. 2012-13) Manish Gupta, H-101, Surya Vihar Complex, Near Kapashera Border, Gurgaon, Haryana 122016 ...... अपीलार्थी/Appellant Pan: Amppg-7521-B बिाम Vs. Income Tax Officer, Ward-2(4), ..... प्रनिवादी/Respondent Gurgaon, Haryana 122016 अपीलार्थी द्वारा/Appellant By : Shri Chandresh Gupta & Ms. Manisha Lahoti Chartered Accountants प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 16/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against An Ex-Parte Order Of Joint/Additional Commissioner Of Income Tax (Appeals), Agra [In Short ‘The Cit(A)’] Dated 12.09.2025, For The Assessment Year 2012-13. 2. Shri Chandresh Gupta, Appearing On Behalf Of The Assessee Submits That The Assessment Was Reopened On The Basis Of Information Received From The Investigation Wing Alleging Investment In Immovable Property Amounting To Rs. 80,86,553/-. In Reassessment Proceedings, The Assessee Explained Source Of Investment. The Ao Accepted Source Of Entire Investments Except Rs.15,00,000/-. The Assessing Officer (Ao) Held That An Amount Of Rs.15,00,000/- Stated To Be Sale

For Appellant: Shri Chandresh Gupta & Ms. Manisha LahotiFor Respondent: Shri Manoj Kumar, Sr. DR
Section 69A

proceeds of jewellery, routed through the bank account of the assessee’s sister, remained unexplained. The Assessing Officer treated the said amount as unexplained money u/s 69A of the Act and added the same to the total income of the assessee. The assessee filed an appeal before

Poonam Sodhi, Gurgaon vs. ITO, Gurgaon

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 7105/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Dec 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.7105/धिल्ली/2025 (नि.व. 2017-18) Poonam Sodhi, 5217, Dlf Phase Iv, Dlf City, Gurgaon, Haryana 122002 ...... अपीलार्थी/Appellant Pan: Bfvps-5961-R बिाम Vs. Income Tax Officer, Hsiidc Building, Vanijya Nikunj, Udhyog Vihar, Phase-V, ..... प्रनिवादी/Respondent Gurgaon, Haryana 122001 अपीलार्थी द्वारा/Appellant By : Shri Saurabh Sharma, Advocate प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 15/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Additional/Joint Commissioner Of Income Tax (Appeals)-2, Vododara [In Short ‘The Cit(A)’] Dated 04.07.2024, For Assessment Year 2017-18. 2. Shri Saurabh Sharma, Appearing On Behalf Of The Assessee Submits That The Assessee Filed Her Return Of Income For The Assessment Year Under Consideration Declaring Total Income Of Rs. 8,03,000/- Comprising Of Income From House Property & Interest Income. The Case Was Selected For Limited Scrutiny Under Cass To Examine Large Cash Deposits During Demonetization Period Vis-À-Vis The Returned Income. Statutory Notices U/S. 143(2) & 142(1) Of The Income Tax

For Appellant: Shri Saurabh Sharma, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 143(2)Section 250Section 250(6)Section 69A

satisfied with the explanation furnished by the assessee and treated the entire cash deposit of Rs. 29,26,000/- as unexplained money under section 69A of the Act. Aggrieved, the assessee filed an appeal before the CIT(A). The CIT(A), without adjudicating the issues on merits, dismissed the appeal

Surender Singh Sangwan, Delhi vs. ITO Ward-4, Sonipat

In the result, appeal of the assessee is partly allowed

ITA 1639/DEL/2025[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2016-17] Surender Singh Sangwan Vs Ito C/O-Kapil Goel, Advocate Ward-4, Aayakar F-26/124, Sector-7 Bhawan, Sonepat, Rohini, Delhi-110085 Haryana Pan-Bqsps5616M Appellant Respondent Appellant By Dr. Kapil Goel Respondent By Shri Manish Gupta, Sr. Dr Date Of Hearing 18.09.2025 Date Of Pronouncement 12.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 06.12.2024 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Rohtak/10489/2018-19 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 27.12.2018 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That Assessee E-Filed His Return Of Income, Declaring Total Income At Inr 7,00,190/-. The Case Was Selected For Scrutiny Through Cass & Notice U/S 143(2) Was Issued To The Assessee On 07.07.2017 & Duly Served Upon The Assessee. Thereafter, Notices U/S 142(1) Of The Act Alongwith Questionnaire Were Issued On 25.04.2018. In Response Assessee Has Filed Reply Which Were Considered By The Ao & The Assessment Order Was Passed U/S 143(3) Of The Act Dated 27.12.2018 Wherein The Total Income Stood Assessed At Inr 1,12,94,400/- By Making Addition U/S 68 Of The Act Towards Unsecured Loans Of Inr 1,05,00,000/- Received During The Year Under Appeal. Besides Disallowance Of Rs. 94,210/- Out Of Various Expenses Claimed Is Also Made.

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

field enquiry was made by deputing ward inspector and made the addition of unsecured loans 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 in [1986] 159 ITR 78 (SC). Ld.AR ... made any independent inquiries and sit on the same with folded hands, it cannot be said that the loans taken are not genuine and unexplained money of the assessee. Thus by respectfully following the judgements of hon’ble jurisdictional high court and of other high courts and of the Tribunal