“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

Grenic Tiles Private Limited, Wankaner-Morbi vs. Asst.Commissioner of Income-Tax Circle 1(1) RKT, Rajkot

The appeal of the assessee is allowed, whereas

ITA 624/RJT/2025[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 624/Rjt/2025

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 133(6)Section 143(3)Section 250Section 68

facts of the case. (2). The learned CIT (A) has erred in sustaining the addition of Rs.13,30,729/- to the returned income as unexplained money u/s.68 of the Act. (3). The learned CIT(A) has erred in not accepting the source of cash deposit aggregating to Rs.13

Liverpool Fashions Limited, Ahmedabad vs. The ITO, Ward-2(1)(3), Ahmedabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 644/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad11 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115BSection 144Section 250Section 69A

explain the cash deposit and credit entries appearing in the bank account, the AO made total addition of Rs.2,19,50,000/- as unexplained money u/s.69A of the Act and assessed to tax u/s.115BBE of the Act @ 60%. 6. Aggrieved against the same, the assessee filed appeal before the Ld.CIT

ACIT., Central Circle-1(4), Hyderabad vs. Kvr Consultancy Private Limited, Hyderabad

In the result, the appeal filed by the Revenue is dismissed

ITA 212/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Section 132Section 142(1)Section 147Section 148Section 251

support of its contentions and the reasons given by the A.O. to make addition towards unsecured loan from M/s. Opus Holdings Private Limited as unexplained money under Section 69 of the Income Tax Act, 1961. There is no dispute with regard to the fact that the assessee company has received ... without appreciating the relevant facts, and only suspicion, made addition towards loan received by the assessee company from M/s. Opus Holdings Private Limited as unexplained money under Section 69 of the Income Tax Act, 1961. 13. Insofar as the argument of the learned Senior A.R. for the Revenue in light

Dayachary Ponnekanti, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

ITA 1985/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia(In आयकर अपीलसं./I.T.A. No.1985/Hyd/2025 (निर्धारणवर्ष/ Assessment Year:2016-17) Dayachary Ponnekanti, Hyderabad. Pan: Ahspp5496L Vs. Dcit, Circle-1(1), Hyderabad. (अपीलार्थी/ Appellant) (प्रत्यर्थी / Respondent) करदाताकाप्रतिनिधित्व/ Assessee Represented By राजस्वकाप्रतिनिधित्व/ Department Represented By सुनवाईसमाप्तहोनेकीतिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/ Date Of Pronouncement Shri H. Srinivasulu, Advocate Shri Mathivanan S A, Sr. Ar 02/03/2026 11/03/2026 Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Dayachary Ponnekanti, ("The Assessee"), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)") Dated 08/10/2025 For The A.Y.2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 143Section 144Section 147Section 148Section 148ASection 69Section 69A

erred in confirming the addition of Rs.1,06,00,000/- made by the Ld. AO under section 69A as unexplained money. The assessee borrowed from friends and relatives and loans are genuine 9. Without prejudice to above, the appellant requests for an epportunity of proving the loans with documentary evidence

Seenaiah Boddupalli, Hyderabad vs. DCIT., Central Circle 2(4), Hyderabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1168/HYD/2025[2020-21]Status: DisposedITAT Hyderabad11 Mar 2026AY 2020-21

Bench: him which are proper documents and crucial evidence for disposing the appeal in favour of the appellant.

Section 131Section 142(1)Section 250

order passed by the A.O. in making addition towards cash found and seized by the department under Section 69A of the Act, as unexplained money and bringing the same to tax under Section 115BBE of the Income-tax Act, 1961. 6. Aggrieved by the order

Pabbareddy Kodandaramireddy, Nellore vs. Income Tax Officer, Ward-2, Nellore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 527/HYD/2023[2017-2018]Status: DisposedITAT Hyderabad11 Mar 2026AY 2017-2018

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 69Section 69A

taking note of the reasons given by the A.O., rejected the explanation of the assessee and sustained the addition made by the A.O. towards unexplained money under Section 69 of the Income Tax Act, 1961 towards cash deposit into bank account and also addition towards unexplained investment under Section

Arch Tech Building Materials Private Limited, Cuddalore vs. ITO, Ward 1, Cuddalore

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

ITA 4044/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Mar 2026AY 2015-16

Bench: SHRI GEORGE GEORGE K (Vice President), SHRI INTURI RAMA RAO (Accountant Member)

Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 148ASection 250Section 282(1)

Rs.64,14,000/-. While doing so, the Assessing Officer(AO) made addition of cash deposits in current account of Rs.64,06,000/- as unexplained money of the Appellant Company. The Assessing Officer also made addition of Rs.8,000/- being interest income received from Prism Cement Limited. 3. Being Aggrieved

C-2480 Elayangaram Paccs, Tirupattur vs. ITO, Tirupathur

In the result, appeal of the Assessee stands partly allowed for statistical purpose

ITA 4037/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Mar 2026AY 2018-19

Bench: Shri George George K, Vice- & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.4037/Chny/2025 "नधा"रण वष" / Assessment Year: 2018-19 C-2480 Elayanagaram Assessment Unit, Primary Agricultural V Nfac, Income Tax Cooperative Credit Society, S. Department, Elayanagaram, Tirupattur. Ito-Che-W- Pan: Aahfc7142G (146)(2), Chennai. Appellant Respondent Assessee By Mr. Shyam Sundar – Ca Revenue By Ms. V Awasthay – Jcit Date Of Hearing 17/02/2026 Date Of Pronouncement 11/03/2026 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax(Appeals)[Nfac] Delhi [‘The Cit(A)’] Passed Under Section 250 Of The Income Tax Act

Section 115BSection 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 250(6)Section 69Section 80P(2)(a)

Rs.51,16,436/-. While doing so, the Assessing Officer made addition on cash deposit in the current account maintained with IDBI Bank on unexplained money of the appellant. 4. Being aggrieved by the above assessment order, the appellant preferred an appeal before the ld.CIT(A) with a delay

Lakshmanappa Parameshwarappa Prakash, Chikkamagaluru vs. ACIT, Hassan

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

ITA 2271/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Roshan Manssor, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 142(1)Section 250Section 68

assessee are ITA No.2271 /Bang/2025 Page 2 of 7 interconnected and relate to the addition made on account of cash deposits treated as unexplained money under section 68 of the Act. 3. The brief facts of the case are that the assessee, an individual, is engaged in the business

Hasina Mohammad Haji Shaikh, Nanded vs. Assessing Officer, Nanded

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

ITA 2295/PUN/2025[2017-18]Status: DisposedITAT Pune10 Mar 2026AY 2017-18

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2295/Pun/2025 Assessment Year : 2017-18 Hasina Mohammad Haji Shaikh, Vs. The Income Tax Officer, 44, Taroda Bk, Ashirwad Nagar, Ward-2, Nanded Nanded – 431605, Maharashtra Pan : Aymps0281R Appellant Respondent

For Appellant: Shri Shaikh BashiruddinFor Respondent: Shri Dayanand Jawalikar

Section 142(1)Section 143Section 69A

assessee is that ld.CIT(A) erred in confirming the action of the Assessing Officer making addition of Rs.12,04,000/- on account of unexplained money u/s.69A of the Act and undisclosed bank interest at Rs.36,542/-. 3. Brief facts of the case are that the assessee is a salaried employee ... failed to succeed. Now the assessee is in appeal before this Tribunal. 5. Ld. Counsel for the assessee only argued on the addition for unexplained money u/s.69A of the Act at Rs.12,04,000/- reiterating the submissions made before both the lower authorities and prayed for deletion of the impugned

Asirvad Micro Finance Limited, Anna Salai vs. Deputy Commissioner of Income Tax, Corporate Circle -1(1), Chennai

The appeal of the assessee is partly allowed

ITA 1139/CHNY/2025[2015-16]Status: DisposedITAT Chennai10 Mar 2026AY 2015-16

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.1139/Chny/2025 िनधा$रण वष$ /Assessment Year: 2015-16

For Appellant: Mr. P.R. Prasanna Varma, FCAFor Respondent: Mr. Bipin C.N., CIT

Section 250Section 56(2)(viib)

proof on closely held companies for funds received from shareholders as well as taxing share premium in excess of fair market value. * Taxing of unexplained money, credits, investments, expenditures etc., at the highest rate of 30%., irrespective of the slab of income." 8. From the above observations

Pramod Subbiahnapalya Venkatpathi, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

In the result, all the appeals filed by the assessee are allowed

ITA 680/BANG/2025[2020-21]Status: DisposedITAT Bangalore10 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR

Section 132Section 142(1)Section 153CSection 69

treated a sum of Rs. 6,00,000/- as not supported by any source and therefore treated the said Rs. 6,00,000/- as unexplained money u/s. 69 of the Act. Except the sale agreement, no other records were found and seized by the authorities and even the major part ... paid by cash for which the assessee was not able to give the source and therefore the AO had treated the said amount as unexplained money u/s. 69 of the Act in respect of the A.Y. 2015-16. Apart from the said documents, no other incriminating materials / documents were seized

Pramod Subbiahnapalya Venkatpathi, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

In the result, all the appeals filed by the assessee are allowed

ITA 679/BANG/2025[2019-20]Status: DisposedITAT Bangalore10 Mar 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR

Section 132Section 142(1)Section 153CSection 69

Pramod Subbiahnapalya Venkatpathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

In the result, all the appeals filed by the assessee are allowed

ITA 678/BANG/2025[2018-19]Status: DisposedITAT Bangalore10 Mar 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR

Section 132Section 142(1)Section 153CSection 69

Pramod Subbiahnapalya Venkatathi, Bangalore vs. DCIT, Central Circle -2(1), Bangalore

In the result, all the appeals filed by the assessee are allowed

ITA 677/BANG/2025[2017-18]Status: DisposedITAT Bangalore10 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR

Section 132Section 142(1)Section 153CSection 69

Pramod Subbiahnapalya Venkatathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

In the result, all the appeals filed by the assessee are allowed

ITA 676/BANG/2025[2016-17]Status: DisposedITAT Bangalore10 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR

Section 132Section 142(1)Section 153CSection 69

Pramod Subbiahnapalya Venkatpathi, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

In the result, all the appeals filed by the assessee are allowed

ITA 675/BANG/2025[2015-16]Status: DisposedITAT Bangalore10 Mar 2026AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Vinay Simha, CAFor Respondent: Shri Subramanian, JCIT-DR

Section 132Section 142(1)Section 153CSection 69

Deputy Commissioner of Income Tax Central Circle 5(3), Mumbai vs. Sanghvi Dhanrupji Devaji & Co., Mumbai

In the result, the appeal filed by the revenue stands dismissed

ITA 6015/MUM/2025[AAQFS6338H]Status: DisposedITAT Mumbai10 Mar 2026

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Prusethdeputy Commissioner Of Vs. Sanghvi Dhanrupji Income Tax Central Circle Devaji & Co. 5(3), Mumbai 33, Mumba Devi Road, Room No. 426, 4Th Floor, Dagina Bazar, Kautilya Bhavan, Mumbai- 400002 Mumbai- 400051 Pan/Gir No. Aaqfs6338H (Applicant) (Respondent) Assessee By Shri M B Sanghvi Revenue By Ms. Kavitha Kaushik,Sr.Dr. Date Of Hearing 21.01.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Revenue Challenging The Impugned Order Dated 23.12.2024 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2014-15. The Revenue Has Raised The Following Grounds Of Appeal: 1. Ground I - Whether On The Facts & The Circumstances Of The Case & In Law, The Cit(A) Erred In Deleting/Allowing Relief In Respect Of The Addition Of Rs.

Section 250Section 40A(3)(a)Section 68

concocted cash sale has been booked by the assessee just before the demonetization period to adjust and to bring into books, its undisclosed and unexplained money generated through out of books activities. 5.1 Assessee has manipulated books of account to adjust his undisclosed money. 5.2 Assessee has pretended that ... Hence, AO held that purchases of old ornaments in cash are used as colourable device to inflate the stock and to justify introduction of unexplained money during demonetization. The AO has also mentioned that the assessee has sold gold bullion of Rs.1,72,82,000/- of different small weights

Upsrtc Emp Salary Person Co-Op Lone Samiti Limited, Haridwar vs. ITO, Circle1(3)(1), Haridwar

In the result, the appeal of the assessee is allowed

ITA 2/DDN/2026[2017-18]Status: HeardITAT Dehradun09 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2017-18] Upsrtcc Emp. Salary Vs Ito Person Co-Op Loan Samiti Ward-1(3)(3) Ltd., Haridwar Bus Stand, Haridwar Haridwar, Uttarakhand Uttarakhand Pan-Aaaau9031C Appellant Respondent Appellant By Shri Rajiv Sahni, Ca Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 09.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 04.12.2025 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-10, Mumbai [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.11.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Before Us, Ld.Ar For The Assessee Submits That During The Period Of Demonetization, Assessee Society Has Deposited 12,98,000/- In Specified Bank Notes (“Sbn”) Which Was Claimed To Have Been Received As Recovery Of The Loans From Its Members However, The Ao Has Made The Addition By Treating The Same As Unexplained Money. Ld.Ar Further Submits That Entire Sum Was Received As A Recovery Of Loans Given To Its Members & Necessary Copy Of Cash Book Alongwith Cash Flow Statement Was Submitted However, These Were Not Appreciated By Ao But Ld. Cit(A) Had Allowed The Part Relief Of Inr 8,30,000/- & Sustained The Balance Amount. Ld.Ar Submits That Sole Basis For Confirming The Addition Is Non-Production Of The Receipts. Ld.Ar Submits That Once The Books Of Accounts Have Been Accepted Wherein Cash Received From Members Is Duly Recorded, No Addition Is Required To Be Made. He Prayed Accordingly.

Section 143(3)Section 250

have been received as recovery of the loans from its members however, the AO has made the addition by treating the same as unexplained money. Ld.AR further submits that entire sum was received as a recovery of loans given to its members and necessary copy of cash book alongwith cash

Vaibhav Corporation, Surat vs. Income Tax Officer, Ward 3(2)(1), Surat

The appeal of the assessee is treated as allowed for statistical purposes

ITA 775/SRT/2025[2017-18]Status: DisposedITAT Surat09 Mar 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No. 775/Srt/2025 िनधा"रण वष" /Assessment Year : 2017-18 Vaibhav Corporation The Income Tax Officer बनाम 114/2/1, Vaibhav Corporation Ward-3(2)(1) / Dabholi, Katargam Surat 0 395 001 V/S. Surat – 395 004 "थायी लेखा सं./Pan: Aanfv 6268 J (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Ms. Chaitali Shah, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 21/05/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2017-18. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Vaibhav Corporation Vs. Ito Asst. Year : 2017-18

For Appellant: Ms. Chaitali Shah, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 115BSection 147Section 148Section 148ASection 250Section 69A

subject, the assessing officer has erred in making addition of Rs. 37,22,000 u/s. 69A on account of alleged unexplained money. 6. On the facts and circumstances of the case, as well as the law on the subject, the assessing officer has erred in taxing the addition by taking