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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

Rakesh Jain, Mumbai vs. National Faceless Appeal Centre (NFAC), Delhi

In the result the appeal filed by the assessee stands allowed

ITA 546/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarι.Τ.Α. No.546/Mum/2025 A.Y: 2017-18 Rakesh Jain Vs Dcit - 26(1) Shop No. 29, 2Nd Floor, Kautilya Bhavan, 126-128, Sheikh Menon Bandra, Mumbai St., Trimurti Estate, Kalbadevi, Mumbai Pan – Aaιρj7359P (Appellant) (Respondent) Assessee By | Shri Vimal Punmiya Revenue By || Shri Annavaran Kosuri, Sr. Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 04.12.2025 Order Per: Shri. Sandeep Gosain, J.M.: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dt.28.11.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (‘The Act'), By The National Faceless Appeal Centre (Nfac) / Cit(A) For The

Section 115Section 144Section 145Section 156Section 250Section 274Section 68

complete year cash book, names, addresses and telephone numbers of person to whom cash sales were made, such sales could not be considered as unexplained money and that too when profit derived from those sales proceeds was already taxed as part of sales Vs Income-tax Officer IT APPEAL ... ASSESSMENT YEAR 2017-18] Section 68, read with section 145, of the Income-tax Act, 1961 - Cash credit (Unexplained money) Assessment year 2017-18 Assessee deposited cash of Rs.50 lakhs in his bank account during period of demonetization He contended that same were proceeds of cash sales Assessing Officer observed

Sh. Vivek Gupta, Haryana vs. ACIT/DCIT, Haryana

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

ITA 5037/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2018-19] Shri Vivek Gupta Vs Acit/Dcit C-5/2A, Opp. C. C. Colony Central Circle Rana Pratap Bagh, North Delhi Karnal Delhi-110007 Pan-Aappg4029A Appellant Respondent Appellant By Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Respondent By Ms. Amisha S.Gupt, Cit Dr Date Of Hearing 04.12.2025 Date Of Pronouncement 04.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 29.07.2025 By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.10453/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2019 Passed U/S 143(3) R.W.S. 153B(1)(B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That A Search & Seizure Operation U/S 132 Were Carried Out At The Business Premises Of M/S. Oswal Group Of Cases, Karnal & Residential Premises Of Its Members On 22.01.2018. The Case Of The Assessee Was Also Covered U/S 132 Of The Act. Assessee Filed His Return Of Income On 28.07.2018 Declaring Total Income Of Inr 13,36,300/-. Thereafter, Statutory Notice U/S 143(2) Of The Act Was Issued On 23.04.2019 Followed By Notices U/S 142(1) Of The Act Alongwith Questionnaire Issued From Time To Time. In Response To Above, Assessee Filed Replies. Thereafter, The Ao Passed The Assessment Order U/S 143(3) R.W.S. 153B(1)(B) Of The Act Dated 29.12.2019 Assessing Total Income Of The Assessee At Inr 81,59,730/-.

Section 115BSection 132Section 142(1)Section 143(2)Section 143(3)Section 153DSection 250Section 69Section 69A

personal saving of the assessee out of the drawings made for household expenses. It is thus, prayed that the addition made towards cash as unexplained money be deleted. 8. On the other hand, Ld. CIT DR for the Revenue vehemently supported the orders of the lower authorities and submits that ... cash found during the search and the explanation now tendered is an afterthought. Therefore, the cash found during the course of search is unexplained money of the assessee and requested for the confirmation of the addition made. 9. Heard the contentions of both parties and perused the material available

Gunjan Enterprises, Junagarh vs. Income Tax Officer, Bhawanipatna

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 440/CTK/2025[2017-18]Status: DisposedITAT Cuttack03 Dec 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.440/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2017-18) Gunjan Enterprises, Main Road, Vs Income Tax Officer, Bhawanipatna Junagarh, Junagarh, Kalahandi Pan No. : Aaqfg 0439 H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Manoj Kumar Sultania, Ca राज"व क" ओर से /Revenue By : Shri Vijaya Singh, Ld Sr Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement आदेश / O R D E R Per Bench :

For Appellant: Shri Manoj Kumar Sultania, CAFor Respondent: Shri Vijaya Singh, ld Sr DR

submitted by ld AR that the issue in the appeal was against the action of the ld CIT(A) in confirming the addition of unexplained money deposited in the assessee’s bank account to an extent of Rs.37,06,103/-. It was the submission that the sales shown ... from the sale, VAT to an extent of Rs.26.96 lakhs was reduced and the difference of Rs.37.06 lakhs was treated by the AO as unexplained money. It was the submission that the purchase and sale for the period 1.7.2016 to 30.9.2016 was unfortunately entered in the partner’s current account

Msl Fish Traders Private Limited, Bhubaneswar vs. Dy.CIT, Central Circle-2, Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 333/CTK/2025[2018-2019]Status: DisposedITAT Cuttack03 Dec 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.332 & 333/Ctk/2025 ("नधा"रण वष" / Assessment Years: 2017-18 & 2018-19) Msl Fish Traders Private Limited, Vs Dcit, Central Circle-2, Rooom No.14, Fish Market, Unit-4, Bhubaneswar. Bhubaneswar. Pan No. : Aajcm 1080 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri D.Parida, Ca & Shri Chitrasen Parida, Adv राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Ld Cit Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 3 /12/2025 आदेश / O R D E R Per Bench : These Are Appeals Filed By The Assessee Against The Separate Orders Dated 31.3.2025 Passed By Ld Cit(A), Bhubaneswar-2 In Appeal No.Cit(A), Bhubaneswar-2/11252/2017-18 For The Assessment Years 2017-18 & 2018-19, Respectively. 2. Shri D.Parida & Shri Chitrasen Parida, Ld Ars Appeared For The Assessee & Shri Ashim Kumar Chakraborty, Ld Cit Dr Appeared For The Revenue. 3. It Was Submitted By Ld Ar That The Assessee Has Filed Written Submission, Which Reads As Follows:

For Appellant: Shri D.Parida, CA and Shri ChitrasenFor Respondent: Shri Ashim Kumar Chakraborty, ld CIT
Section 132Section 153ASection 246ASection 250Section 69

appellant vide Order dated 31.03.2025, upheld the addition in respect of land of Rs.74,00,000/- and Commission income of Rs.84,67,864/- as unexplained money. 4. That, being aggrieved against the abovesaid appeal order passed by the Id. CIT(A), the appellant has come up before your Honour with ... basis of loose sheets on presumption and added a sum of Rs. 84,67,864/- to which the learned CIT(Appeals) has confirmed as unexplained money u/s 69A of the Act without having any corroborated evidences, without considering the remand report remarks and without considering the submission made

Msl Fish Traders Private Limited, Bhubaneswar vs. Dy.CIT, Central Circle-2, Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 332/CTK/2025[2017-2018]Status: DisposedITAT Cuttack03 Dec 2025AY 2017-2018

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.332 & 333/Ctk/2025 ("नधा"रण वष" / Assessment Years: 2017-18 & 2018-19) Msl Fish Traders Private Limited, Vs Dcit, Central Circle-2, Rooom No.14, Fish Market, Unit-4, Bhubaneswar. Bhubaneswar. Pan No. : Aajcm 1080 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri D.Parida, Ca & Shri Chitrasen Parida, Adv राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Ld Cit Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 3 /12/2025 आदेश / O R D E R Per Bench : These Are Appeals Filed By The Assessee Against The Separate Orders Dated 31.3.2025 Passed By Ld Cit(A), Bhubaneswar-2 In Appeal No.Cit(A), Bhubaneswar-2/11252/2017-18 For The Assessment Years 2017-18 & 2018-19, Respectively. 2. Shri D.Parida & Shri Chitrasen Parida, Ld Ars Appeared For The Assessee & Shri Ashim Kumar Chakraborty, Ld Cit Dr Appeared For The Revenue. 3. It Was Submitted By Ld Ar That The Assessee Has Filed Written Submission, Which Reads As Follows:

For Appellant: Shri D.Parida, CA and Shri ChitrasenFor Respondent: Shri Ashim Kumar Chakraborty, ld CIT
Section 132Section 153ASection 246ASection 250Section 69

appellant vide Order dated 31.03.2025, upheld the addition in respect of land of Rs.74,00,000/- and Commission income of Rs.84,67,864/- as unexplained money. 4. That, being aggrieved against the abovesaid appeal order passed by the Id. CIT(A), the appellant has come up before your Honour with ... basis of loose sheets on presumption and added a sum of Rs. 84,67,864/- to which the learned CIT(Appeals) has confirmed as unexplained money u/s 69A of the Act without having any corroborated evidences, without considering the remand report remarks and without considering the submission made

Vasanthi Bijjala, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, we find no merit in the appeal filed by the assessee, which, being devoid and bereft of any substance, is dismissed

ITA 1568/HYD/2025[2020-21]Status: DisposedITAT Hyderabad03 Dec 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1568/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) Vasanthi Bijjala, Vs. Acit, Hyderabad. Central Circle-2(1), Pan: Afipb2336M Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Date Of 03/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Cit(Appeals)-12, Hyderabad, Dated 15.07.2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 153C R.W.S. 144 Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 25.02.2025, For The Assessment Year 2020-21. The Assessee Has Assailed The Impugned Order Of The Cit(Appeals) On The Following Grounds Of Appeal Before Us:

For Appellant: Shri Y.V. Bhanu NarayanFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 142(1)Section 144Section 153CSection 234ASection 250Section 69A

seized material viz., Annexure A/SIEPL/OFF/22, Pages 130–138, and treated the assessee’s share of Rs. 2,10,600/- (3.51%) as her unexplained money under Section 69A of the Act. Accordingly, the AO vide his order passed under Section 153C r.w.s.144 of the Act assessed the income of the assessee

Syed Mohammed Asad Ullah Hussaini, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

Accordingly, the appeal filed by the assessee is dismissed

ITA 268/HYD/2024[2016-17]Status: DisposedITAT Hyderabad03 Dec 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.268/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Syed Mohammed Asad Vs. Acit, Ullah Hussaini, Central Circle-2(3), Hyderabad. Hyderabad. Pan: Abfph0148G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao राज" व "ारा/Revenue By: Shri Gurpreet Singh, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 13/10/2025 घोषणा की तारीख/Date Of 03/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Cit(Appeals)-12, Hyderabad, Dated 14.09.2023, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, ”Ao”) Under Section 143(3) R.W.S. 153C Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 28.03.2022, For The Assessment Year 2016- 17. The Assessee Has Assailed The Impugned Order Of The Cit(Appeals) On The Following Grounds Of Appeal Before Us.

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr.AR
Section 132Section 143(3)Section 153ASection 250Section 69

issued show-cause notices (SCN’s) proposing certain additions, viz. (i) Rs. 35 lakhs, i.e., 1/5th of Rs. 1.75 crores (supra) as unexplained money under Section 69A of the Act; and (ii) Rs. 25 lakhs (supra) as unexplained investment under Section 69 of the Act. The assessee submitted that ... even before us. We, thus, find no infirmity in the action of the AO in treating Rs. 35 lakhs as unexplained money under Section 69A of the Act and Rs.25 lakhs as unexplained investment under Section 69 of the Act. 20. We note that the assessee has also raised several

Narayan Das Damani, Kolkata vs. ITO, Ward 44(1), Kolkata

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

ITA 2185/KOL/2025[2019-2020]Status: DisposedITAT Kolkata03 Dec 2025AY 2019-2020

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2185/Kol/2025 Assessment Year: 2019-20 Narayan Das Damani.……….…………………....…………………....Appellant C/O Subash Agarwal & Associates, 1, Gibson Lane, Suite 213, 2Nd Floor, Kol-69.. [Pan: Agxpd4817F] Vs. Ito, Ward-44(1), Kolkata..……………....…..………………….…..... Respondent Appearances By: Shri Siddharth Agarwal, Ar, Appeared On Behalf Of The Appellant. Shri Pampa Ray, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 01, 2025 Date Of Pronouncing The Order : December 03, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Hereinafter Referred To As “Ld. Cit(A)”) Dated 25.07.2025 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 Runs Proprietary Concern M/S Oriental Industries As Dealer Of Wires & Cables. During The Year Ended 31.03.2019 The Appellant Submitted Return Of Income Showing Total Income 368070 Which Was Accepted Under Sec 143(1) Vide Order Dated 21.02.20. A Return Was Also Filed On 06.09.23 & The Assessing Authority Had Information That M/S Aerocom Trade Exim Was Found Indulging In Issuance Of Fraudulent Gst Bills The Appellant Has

Section 250Section 69ASection 69C

submissions on e-filing site and he could not submit responses. The Assessing Officer made additions of Rs.2623000/- as impugned bogus sale as unexplained money u/s 69A and Rs. 472229/- (being the GST amount on above value) as bogus expenditure u/s 69C. thereby causing grave injustice. 3. Against the order