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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

Mohd Akram Abdul Latif Ansari, Bhiwandi vs. Income Tax Officer Ward 1(1), Kalyan

ITA 3970/MUM/2025[2017-18]Status: DisposedITAT Mumbai03 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Mohd. Akram Abdul Latif Ansari Ito Ward 1(1) Gala No. 02, Mh No. 71, More Mohan Plaza, Near Building, Kotergate Road Vs. Poddar School Kap Kaneri, Bhiwandi Wayale Nagar, Thane, Maharashtra-421 302. Khadagpada, Kalyan Pan : Adnpa2221M Appellant Respondent

For Appellant: Shri Pravin SalunkheFor Respondent: Shri Punit Jhabak
Section 142(1)Section 69A

presumed that there is no explanation to offer and part of the money deposited in the savings bank account (Rs. 32.6 lakh) as unexplained money under section 69A of the Act. Apart from this, the Ld. AO made addition of Rs. 15.7 lakh as profit under the head ‘business income

Anukool Gas Service, Mumbai vs. ITO Ward 20(1)(1), Mumbai

ITA 3402/MUM/2025[2017-18]Status: DisposedITAT Mumbai03 Dec 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Vimal Punmiya, AR
Section 133(6)Section 142(1)Section 250Section 269SSection 271ASection 68

been included in the P/L account and hence has escaped assessment. The amount of Rs.54,06,202/- is added to the total income as unexplained money u/s 69A of the Act. Penalty proceedings u/s 271AAC(1) for under-reporting of income are initiated separately. 9. Subject to the above remarks

DCIT Central Circle-1, Noida vs. Nivedan Fin-Invest Lease Ltd., Delhi

In the result, Revenue’s appeal is dismissed

ITA 1713/DEL/2023[2015-16]Status: DisposedITAT Delhi03 Dec 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2015-16

Section 115BSection 133(6)Section 147Section 148Section 151Section 69A

1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E ”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI

Assistant Commissioner of Income Tax, Circle - Shillong, Shillong vs. Shri Chandra Mohan Jha, Shillong

Appeals are partly allowed

ITA 78/GTY/2018[2013-14]Status: DisposedITAT Guwahati02 Dec 2025AY 2013-14

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 69Section 69A

facts and in the circumstances of the case, the Ld.CIT(A) erred in deleting an addition of Rs.20,86,67,681/- as unexplained money in undisclosed bank account of the assessee u 69A of the IT Act. 4. Whether on the facts an in the circumstances of the case

Shri Chandra Mohan Jha, Shillong vs. Assistant Commissioner of Income Tax, Circle - Shillong, Shillong

Appeals are partly allowed

ITA 62/GTY/2018[2013-14]Status: DisposedITAT Guwahati02 Dec 2025AY 2013-14

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 69Section 69A

facts and in the circumstances of the case, the Ld.CIT(A) erred in deleting an addition of Rs.20,86,67,681/- as unexplained money in undisclosed bank account of the assessee u 69A of the IT Act. 4. Whether on the facts an in the circumstances of the case

Assistant Commissioner of Income Tax, Circle-Shillong, Shillong vs. Smt. Indu Rani Jha, Shillong

Appeal is partly allowed for statistical purposes

ITA 298/GTY/2018[2013-14]Status: DisposedITAT Guwahati02 Dec 2025AY 2013-14

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 69Section 69A

Whether on the facts and in the circumstances of the case, the Ld.CIT(A) erred in deleting addition of Rs.1,38,05,549/- as unexplained money in assessee's undisclosed bank account u/s 69A of the IT Act. 4. Whether on the facts and in the circumstances of the case ... Ld.CIT(A) erred in deleting total addition of Rs.49,67,291/-as unexplained money in assessee's various undisclosed bank account u/s 69A of the IT Act. 5. Whether on the facts and in the circumstances of the case, the Ld.CIT(A) erred in deleting addition of Rs.11

Rishi L Anandani, Bilaspur vs. Income Tax Officer Ward 1(2) Bilaspur, Aykar Vibhag Vyapar Vihar Road Bilaspur

In the result, appeal of the assessee is allowed

ITA 709/RPR/2025[2017-18]Status: DisposedITAT Raipur02 Dec 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.709/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Rishi L Anandani Bhakt Kawaram Ward, Ward No.20, Sindhi Colony, Bilaspur (C.G.)-495 001 Pan: Aqspa4173C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Rishi L Anandani, AdvocateFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 250(4)Section 68Section 69A

short ‘the Act’) were issued to the assessee and finally, the A.O treating the amount of Rs.4,49,000/- as unexplained money, added the same u/s. 69A of the Act in the hands of the assessee. The A.O observed that the assessee has not furnished any acceptable and cogent explanation

Nazerabibi Nadeem Shama, Surat vs. ITO, Ward 2 (3) (6), Surat

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

ITA 760/SRT/2025[2019-20]Status: DisposedITAT Surat02 Dec 2025AY 2019-20

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.760/Srt/2025 Assessment Year: (2019-20) (Hybrid Hearing) Nazerabibi Nadeem Shama, Vs. Ito, 401, 4Th Floor, Dhoom Palace, Nr. I. P. Ward – 2(3)(6), Mission School, Muglisara, Surat – Surat 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Dbpps2760J (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 13/11/2025 Date Of Pronouncement 02/12/2025

Section 148Section 250Section 69A

Since, the appellant had not filed the return of income, the AO treated Rs. 19,662/- as undisclosed interest income, Rs.71,78,553/- as unexplained money u/s 69A of the Act and added it to the total income of the assessee. 4. Aggrieved by the order of AO, the assessee

Income-Tax Officer, Ward-1(2)(3), Ahmedabad, Aayakar Bhawan, Vejalpur vs. Jasmine Jayantibhai Sanghavi, Ahmedabad

In the result, appeal of the Revenue is dismissed

ITA 1779/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17

Bench: Ms. Suchitra Raghunath Kambleआयकर अपील सं./I.T.A. No. 1779/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2016-17) बनाम/ Income-Tax Officer Jasmine Jayantibhai Ward-1(2)(3), Ahmedabad Sanghavi Vs. 7-F, Swetal Flat, Khanpur Bai Centre, Khanpur, Ahmedabad, Gujarat - 380001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aqcps1433R (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Suresh Chand Meena, Sr. Dr ""यथ" क" ओर से/Respondent By : Shri Sunil Talati, Ar Date Of Hearing 01/12/2025 02/12/2025 Date Of Pronouncement O R D E R The Appeal Is Filed By The Revenue Against The Order Dated 08.08.2025 Passed By The National Faceless Appeal Centre (Nfac), Delhi, For Assessment Year 2016-17. 2. The Grounds Of Appeal Filed By The Revenue Are As Under:

For Appellant: Shri Suresh Chand Meena, Sr. DRFor Respondent: Shri Sunil Talati, AR
Section 133ASection 142(1)Section 147Section 148Section 69ASection 69C

circumstances of the case and in law, the Ld.CIT(A) was justified in deleting the addition made of Rs.1,98,723/- being unexplained money u/s. 69A and Rs.1,987/- as unexplained expenditure u/s 69C (being 1% commission for arranging the entry) without appreciating the fact that the assessee could ... submitted that the Ld. CIT(A) was not correct in deleting the addition as the amount of Rs.1,98,723/- is unexplained money u/s.69A of the Act and Rs.1,987/- was unexplained expenditure u/s.69C of the Act being 1% commission for arranging the entry without appreciating the fact that

Ranna Shashank Shah, Ahmedabad vs. The ITO, Ward-5(2)(3), Ahmedabad

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

ITA 1400/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 143(3)Section 44ASection 69A

with the explanation of the assessee regarding the source of cash deposits. Accordingly, the entire cash deposit of Rs.47,81,000/- was treated as unexplained money and added to the income of the assessee under Section 69A of the Act. The assessment was completed under Section

Kirankumar Amrutlal Shah, Banaskantha vs. The Incometax Officer, Ward-4, Palanpur

In the result, appeal of the assessee is allowed

ITA 1208/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble

For Appellant: Shri M. K. Patel, AdvocateFor Respondent: Shri Suresh Chand Meena, Sr. DR
Section 115BSection 133(6)Section 69A

return with balance sheet, ledger account and other copies. After going through the details, the AO made addition of Rs.10,09,000/- as unexplained money u/s.69A of the Act. 4. Being aggrieved by the assessment order, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) dismissed

Vithoba Dada Shirsath, Nashik vs. ITO Ward2(1) Nashik, Nashik

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

ITA 2352/PUN/2025[2019-20]Status: DisposedITAT Pune02 Dec 2025AY 2019-20

Bench: Ms. Astha Chandra & Shri Dr. Dipak P. Ripote

For Appellant: Shri Rakesh PardeshiFor Respondent: Shri Harish Bist
Section 115BSection 144Section 147Section 148Section 69A

land and loan availed from Bank of baroda for construction of farm house., and therefore, the same were not liable to be treated as unexplained money. 3. On the facts and in the circumstances of the case and in law lower authorities have erred in making an addition ... Unexplained Money, being summations of certain cash deposits/credit entries in bank account by rejecting the appellant’s 2 ITA No.2352/PUN/2025, AY 2019-20 submission and further erred in not appreciating that there were cash withdrawals from the bank account and alternatively appellant was entitled to get credit of such withdrawals

Anakala Sunitha, Hyderabad vs. Income Tax Officer, Ward-9(1), Hyderabad

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

ITA 1504/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad02 Dec 2025AY 2016-2017

Bench: श्री मंजूनाथ जी, माननीय लेखा सदस्य SHRI G. MANJUNATHA, HON’BLE (Accountant Member)

Section 115BSection 148Section 148ASection 69A

said cash deposits despite multiple opportunities including a video- conference hearing. Accordingly, the A.O. treated the cash deposit of Rs. 7,00,000/- as unexplained money under Section 69A of the Income-tax Act, 1961 and added the same to the returned income, applying the provisions of Section 115BBE

Krishna Chandra Das, Twenty Four Parganas South vs. I.T.O., Ward - 25(1), Kolkata

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

ITA 1804/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Dec 2025AY 2019-2020

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2019-20 Krishna Chandra Das..……………..………………….……….……….……Appellant Ramkrishnanagar Laskarpur, Alipore, 24 Parganas (S), W.B - 743515. [Pan: Ajapd6700B] Vs. Ito, Ward-25(1), Kolkata………….…………………….....……...…..…..Respondent Appearances By: Shri B. B. Payra, Advocate, Appeared On Behalf Of The Appellant. Shri Dipu Koley, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 27, 2025 Date Of Pronouncing The Order : December 02, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.06.2025 Of The National Faceless Appeal Centre Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2019–20. 2. Brief Facts Of The Case Are That The Assessee Had Not Filed Original Return Of Income For The A.Y. 2019-20. In The Absence Of Voluntary Compliance, The Assessing Officer Initiated Reassessment Proceedings U/S 147 R.W.S. 144 Of The Act By Making Following Additions:

Section 142(1)Section 147Section 15Section 250Section 272A(1)(d)Section 45Section 56Section 69ASection 69B

Salary Received u/s 15 amounting to Rs. 34,64,292/-. iv. Unexplained Investment U/s 69B amounting to Rs.70,79,999/-. Krishna Chandra Das v. Unexplained Money U/s 69A amounting to Rs. 19,64,920/- 2.1 During the assessment proceedings, the Assessing Officer issued statutory notices but the assessee remained

Govabhai Lakhabhai Rabari, Anjar vs. Income Tax Officer(ITO), Gandhidham

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

ITA 878/RJT/2024[2017-18]Status: DisposedITAT Rajkot01 Dec 2025AY 2017-18

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Kalepesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 115BSection 139(1)Section 142(1)Section 143(2)Section 144Section 234ASection 249(4)(b)Section 250Section 274Section 44A

That, the Ld. CIT(A) has wrongly confirmed addition of Rs. 12,41,000/- on account of unexplained money in the bank account u/s 69A of the I.T. Act, 1961. 5. That, the Ld. CIT(A) has wrongly confirmed addition of Rs. 28,22,558/- on account of estimated ... bank account during the year under consideration. As such the total fund deposited during the year under consideration of Rs.12,41,000/- remains unexplained money, therefore, assessing officer made addition under the provisions of section 69A and 115BBE of the I.T. Act. 6. The assessing officer also noticed that during

Govabhai Lakhabhai Rabari, Anjar vs. Income Tax Officer(ITO), Gandhidham

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

ITA 877/RJT/2024[2017-18]Status: DisposedITAT Rajkot01 Dec 2025AY 2017-18

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Kalepesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 115BSection 139(1)Section 142(1)Section 143(2)Section 144Section 234ASection 249(4)(b)Section 250Section 274Section 44A

That, the Ld. CIT(A) has wrongly confirmed addition of Rs. 12,41,000/- on account of unexplained money in the bank account u/s 69A of the I.T. Act, 1961. 5. That, the Ld. CIT(A) has wrongly confirmed addition of Rs. 28,22,558/- on account of estimated ... bank account during the year under consideration. As such the total fund deposited during the year under consideration of Rs.12,41,000/- remains unexplained money, therefore, assessing officer made addition under the provisions of section 69A and 115BBE of the I.T. Act. 6. The assessing officer also noticed that during

Bhagirathi Krishnan, New Delhi vs. ITO Ward 35(5), New Delhi

ITA 6847/DEL/2025[2016-17]Status: DisposedITAT Delhi01 Dec 2025AY 2016-17

Bench: Shri Pawan Singh(Physical Hearing) Bhagirathi Krishnan, Income Tax Officer, Ward-35(5), C/O-Anil Jain Dd & Co. 611, 6Th Floor, Vs Civic Centre, Surya Kiran Building, 19- K.G. Marg, New Delhi-110002 New Delhi-110001 Pan:Aqzpk1479J Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 254(1)Section 271(1)(c)Section 69

assessment order accepted the investment in time deposit and no addition in assessment was made, however made additions on account of variation qua unexplained money wherein amount did not exceed of Rs.50 lakhs, the notice under section 148 after expiry of three years from the end of the relevant assessment

Sarfaraj Mohmed Balera, Bharuch, Gujarat vs. Income Tax Officer Ward 1(5), Ward (), Bharuch

ITA 112/SRT/2025[2012-13]Status: DisposedITAT Surat28 Nov 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethsigx Stil H./Ita No. 112/Srt/2025 (Ay 2012-13) (Physical Hearing) Sarfaraj Mohmed Balera Income Tax Officer, C5 Madni Park Soc, Bharuch-392 | Gam | Ward-1(5), Bharuch, Aayakar 001 Vs Bhawan, Station Road, [Pan : Bhdpb 6343 N] Bharuch-392 001 Ardtenelf/ Appellant Wef Respondent Pafitdt #1 Sik A /Assessee By Shri Krutarth Desai, Ca Weed Sh Ix S /Revenue By Shri Ajay Uke, Sr-Dr | Aare Ct Artg/Date Of Hearing 01.09.2025 Squinot Bt Arre/Date Of Pronouncement | 28.11.2025

Section 143(3)Section 148Section 254(1)Section 69A

No.112/SRT/2025 (A.Y.12-13) Sarfaraj M Balera 4, The Learned Assessing Officer has misdirected himself in arriving to conclusion that the appellant is having unexplained money of Rs. 10,35,403/- without having any material on record. 5. The Learned Assessing Officer has erred in invoking provision of Section

ACIT, Circle1(3), Surat vs. Ashwinbhai Parsottambhai Patel, Surat

In the result, the appeal of the Revenue is dismissed

ITA 1073/SRT/2024[2017-18]Status: DisposedITAT Surat28 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethsix Stict ¥./Ita No. 1073/Srt/2024 (Ay 2017-18)

Section 143(3)Section 254(1)Section 69A

disprove the cash balance available in the cashbook. In view of the above, the cash deposited into the bank account cannot be treated as unexplained money ITA No.1073/SRT/2024 (A.Y.17-18) Ashwinbhai P Patel u/s 69A of the IT Act. By respectfully following the decision of jurisdictional ITAT, the grounds of appeal ... disprove the cash balance available in the cashbook. In view of the above, the cash deposited into the bank account cannot be treated as unexplained money u/s 69A of the IT Act. By respectfully following the decision of jurisdictional ITAT, the grounds of appeal ITA No.1073/SRT/2024 (A.Y.17-18) Ashwinbhai P Patel

Andhara Pradesh Education and Welfare Infrastructure Development Corporation, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

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

ITA 558/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2020-21

Bench: the Ld. CIT(A). The Ld. CIT(A) dismissed the appeals of the assessee ex-parte for both the assessment years by observing as under:

Section 144BSection 147Section 250Section 69A

case of the assessee was completed by the Assessing Officer by making additions for both the assessment years as under : 2019-20 Unexplained money u/s 69A r.w.s. 115BBE 102,59,90,200 of the Act Interest on fixed deposits 3,03,62,809 Contract Receipts ... Rs.102,59,90,200 made by the assessing officer u/s 69A of the Act by considering the alleged investment in fixed deposits as unexplained money. 4. The learned Commissioner of Income Tax (Appeals) is not justified in sustaining the addition of Rs.3,03,62,809 made by the assessing officer