← All Phrases

“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

Ishtiyaque Ahmed, Kolkata vs. DCIT/ACIT, CC-4(3), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 2071/KOL/2025[2022-2023]Status: DisposedITAT Kolkata08 Dec 2025AY 2022-2023

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

Section 132ASection 139(4)Section 143(2)Section 147Section 148Section 250Section 272A(1)(d)Section 44ASection 69

completed on 28.02.2024 assessing total income at Rs.31,32,660/- by making addition u/s 69A of the Act of Rs.25,00,000/- as unexplained money. 13. Aggrieved by the said order, the assessee preferred an appeal before the ld. CIT(A) wherein the ld. CIT(A) confirmed the addition

Ishtiyaque Ahmed, Kolkata vs. DCIT/ACIT, CC-4(3), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 2070/KOL/2025[2020-2021]Status: DisposedITAT Kolkata08 Dec 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

Section 132ASection 139(4)Section 143(2)Section 147Section 148Section 250Section 272A(1)(d)Section 44ASection 69

completed on 28.02.2024 assessing total income at Rs.31,32,660/- by making addition u/s 69A of the Act of Rs.25,00,000/- as unexplained money. 13. Aggrieved by the said order, the assessee preferred an appeal before the ld. CIT(A) wherein the ld. CIT(A) confirmed the addition

Ishtiyaque Ahmed, Kolkata vs. DCIT/ACIT, CC-4(3), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 2069/KOL/2025[2019-2020]Status: DisposedITAT Kolkata08 Dec 2025AY 2019-2020

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

Section 132ASection 139(4)Section 143(2)Section 147Section 148Section 250Section 272A(1)(d)Section 44ASection 69

completed on 28.02.2024 assessing total income at Rs.31,32,660/- by making addition u/s 69A of the Act of Rs.25,00,000/- as unexplained money. 13. Aggrieved by the said order, the assessee preferred an appeal before the ld. CIT(A) wherein the ld. CIT(A) confirmed the addition

Ishtiyaque Ahmed, Kolkata vs. DCIT/ACIT, CC-4(3), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 2067/KOL/2025[2021-2022]Status: DisposedITAT Kolkata08 Dec 2025AY 2021-2022

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

Section 132ASection 139(4)Section 143(2)Section 147Section 148Section 250Section 272A(1)(d)Section 44ASection 69

completed on 28.02.2024 assessing total income at Rs.31,32,660/- by making addition u/s 69A of the Act of Rs.25,00,000/- as unexplained money. 13. Aggrieved by the said order, the assessee preferred an appeal before the ld. CIT(A) wherein the ld. CIT(A) confirmed the addition

Ishtiyaque Ahmed, Kolkata vs. DCIT/ACIT, CC - 4(3), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 2066/KOL/2025[2020-2021]Status: DisposedITAT Kolkata08 Dec 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

Section 132ASection 139(4)Section 143(2)Section 147Section 148Section 250Section 272A(1)(d)Section 44ASection 69

completed on 28.02.2024 assessing total income at Rs.31,32,660/- by making addition u/s 69A of the Act of Rs.25,00,000/- as unexplained money. 13. Aggrieved by the said order, the assessee preferred an appeal before the ld. CIT(A) wherein the ld. CIT(A) confirmed the addition

Swami Darshanand Institute of Management and Technology, Haridwar vs. ITO, W-1(3)(1), Haridwar

In the result, appeal of the assessee is allowed

ITA 129/DDN/2025[2015-16]Status: DisposedITAT Dehradun05 Dec 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalswami Darshanand Institute Of Income Tax Officer, Management & Technology, Ward-1(3)(1), Gurukul Mahavidyalaya, Vs. Haridwar. P.O. Gurukul Kangi, Jwalpur, Haridwar-249407. Pan:Aalas6789G (Appellant) (Respondent) Assessee By Shri Shalil Agarwal, Sr. Adv. & Shri Salies Gupta, Adv. & Shri Uma Shankar, Adv. Department By Shri Amar Pal Singh, Jcit-Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 05.12.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 19.05.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is A Society Engaged In Imparting Education. The Ao Based On The Information That Assessee Has Deposited Cash Of Rs.93,10,000/- In The Saving Bank Account Maintained With A Central Bank Of India Which Is Not Declared & Thus Case Was Reopened By Issue Of Notice U/S 148 Of The Act. Thereafter, Submissions Were Made By The Assessee Wherein It Is Claimed That This Account Pertained To Other Society & All The Deposits Are Duly

Section 144BSection 147Section 148Section 148ASection 250Section 69A

accepted the claim of the assessee and made the addition of Rs.93,10,000/- u/s 69A of the Act as unexplained money of the assessee. In first appeal, the assessee claimed that the account related to some other society and not pertained to the assessee society. However