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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

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 557/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2019-20

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

Abdulrahiman Abdulkadar, Palakkad vs. ITO, Ward-5, Palakkad

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

ITA 878/COCH/2025[2017-18]Status: DisposedITAT Cochin28 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Abdulrahiman Abdulkadar .......... Appellant 1/519, Chimbukkad P.O., Erimahur, Palakkad [Pan: Ahhpa4212A] Vs. The Income Tax Officer, Wd-5, Palakkad .......... Respondent Assessee By: Shri Aditya Unnikrishnan, Advocate Revenue By: Ms. Neethu S. Sr. Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 24.08.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Engaged In The Business Of Running Travel Agency In The Name & Style Of M/S. Almas Travel & Tours. The Return Of Income For Ay 2017-18 Was Filed On 04.08.2017 Declaring Income Of Rs. 4,03,170/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward-5, Palakkad Vide Order Dated 01.10.2018 Passed U/S. 143(3) Of The Income Tax Act, 1961 (The 2 Abdulrahiman Abdulkadar Act) At Total Income Of Rs. 7,11,170/-. While Doing So, The Ao Made Addition Of Rs. 3,08,000/- On Account Of Cash Deposits Made In Specified Bank Notes (Sbn) During Demonetisation Period As Unexplained Money Of The Appellant For The Failure Of The Appellant To Discharge The Onus Of Proving The Source Of Said Deposits.

For Appellant: Shri Aditya Unnikrishnan, AdvocateFor Respondent: Ms. Neethu S. Sr. DR
Section 143(3)

made addition of Rs. 3,08,000/- on account of cash deposits made in specified bank notes (SBN) during demonetisation period as unexplained money of the appellant for the failure of the appellant to discharge the onus of proving the source of said deposits. 3. Being aggrieved, an appeal

Mukalel Philip Jose, Kannur vs. ITO, Ward-4, Kannur

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

ITA 876/COCH/2025[2011-12]Status: DisposedITAT Cochin28 Nov 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2011-12 Mukalel Philip Jose .......... Appellant Mukalel House, Pushpagiri, Taliparamba Kannur 670141 [Pan: Acnpj4619F] Vs. The Income Tax Officer, Ward-4, Kannur .......... Respondent Assessee By: ------- None ------- Revenue By: Ms. Neethu S. Sr. Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), Thane [Cit(A)] Dated 20.08.2025 For Assessment Year (Ay) 2011-12. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Deriving Income Under The Head ‘Salary’. The Return Of Income For Ay 2011-12 Was Filed On 10.08.2011 Declaring Total Income Of Rs. 2,07,790/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward-4, Kannur (Hereinafter Called "The Ao") Vide Order Dated 23.01.2014 Passed U/S. 143(3) Of The Income Tax Act, 1961 (The Act) At Total Income Of Rs.

For Appellant: ------- None -------For Respondent: Ms. Neethu S. Sr. DR
Section 143(3)Section 69A

After granting benefit of earlier cash withdrawals from the bank account the balance amount of Rs. 16,00,000/- was treated as unexplained money of the appellant for the failure of the 3 Mukalel Philip Jose appellant to offer any satisfactory explanation as to the source of the cash deposits

Income Tax Officer, Aluva vs. Tachethu Yohannan Jose, Pattimattom

In the result, appeal filed by the Revenue is dismissed

ITA 740/COCH/2025[2020-21]Status: DisposedITAT Cochin28 Nov 2025AY 2020-21

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Hon’Ble Manu Kumar Giriआयकर अपील सं./ Ita No.740/Coch/2025 "नधा"रण वष" /Assessment Year: 2020-21 The Income Tax Officer, Tachethu Yohannan Jose, Ward-2, Vs. Thachethu House, Aluva. Pattimattom, Ernanakulam – 683 562. Pan: Akbpj 6727G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Abraham Thomas, C.A ""यथ" क" ओर से /Respondent By : Smt. Leena Lal, Snr Ar सुनवाई क" तार"ख/Date Of Hearing : 06.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 28.11.2025 आदेश / O R D E R Per Manu Kumar Giri ():

For Appellant: Shri Abraham Thomas, C.A ""For Respondent: Smt. Leena Lal, Snr AR
Section 147Section 69A

r.w.s 144 of the Income-tax Act, 1961 (hereinafter “the Act”) dated 07.02.2025 making addition of Rs.84,66,408/- on account of unexplained money u/s.69A of the Act. Aggrieved by the said order, the assessee preferred an appeal before the Ld. CIT(A) who partly allowed the appeal. 3. Aggrieved

Sanjay Soni, Bhanpura Road vs. Income Tax Officer, Mandsaur

Appeal is allowed for statistical purpose

ITA 392/IND/2025[2016-17]Status: DisposedITAT Indore28 Nov 2025AY 2016-17

Bench: Shri B.M. Biyani

Section 144Section 147Section 69A

assessment-order ex-parte to assessee u/s 144 after making an addition of Rs. 52,38,400/- u/s 69A treating the bank deposits as unexplained money for non- representation by assessee during assessment-proceeding. Thereafter, the CIT(A) has also passed order of first appeal ex-parte to assessee

Nilesh Jayantilal Shah, Ahmedabad vs. NFAC, Delhi, Juridis. AO- the ITO, Ward-2(1)(2), Ahmedabad

The appeals of the assessee are allowed for

ITA 908/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 115BSection 144Section 147Section 148Section 234ASection 271(1)(c)Section 69Section 69ASection 69C

account of others, was not explained. The Assessing Officer, therefore, treated the entire deposit of Rs.3,29,98,210/- in the bank account as unexplained money under Section 69 of the Act. Further, the entire debit transaction of Rs.3,21,38,779/- was also treated as unexplained expenditure under Section

Nilesh Jayantilal Shah, Ahmedabad vs. NFAC, Delhi, Juridis. AO- the ITO, Ward-2(1)(2), Ahmedabad

The appeals of the assessee are allowed for

ITA 907/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 115BSection 144Section 147Section 148Section 234ASection 271(1)(c)Section 69Section 69ASection 69C

account of others, was not explained. The Assessing Officer, therefore, treated the entire deposit of Rs.3,29,98,210/- in the bank account as unexplained money under Section 69 of the Act. Further, the entire debit transaction of Rs.3,21,38,779/- was also treated as unexplained expenditure under Section

Dr Pamod Eknathrao Jadhav, Aurangabad vs. ITO, Ward-1(6), Aurangabad

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

ITA 2381/PUN/2025[2017-18]Status: DisposedITAT Pune28 Nov 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2381/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Dr. Pramod Eknathrao Vs. Ito, Ward-1(6), Jadhav, Aurangabad. Row House No.1, Samarth Heritage, Opp. Marathwada Sanskrity Mandal Khadkeshwar, Aurangabad- 431001. Pan : Adfpj4882K Appellant Respondent Assessee By : Shri Pratikh Jha Revenue By : Shri Umesh Phade Date Of Hearing : 26.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.06.2025 Passed By Ld. Addl./Jcit(A)-1, Gurugram [‘Ld. Cit(A)’] For The Assessment Year 2017-18. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied

For Appellant: Shri Pratikh JhaFor Respondent: Shri Umesh Phade
Section 10(1)Section 143(2)Section 143(3)Section 250Section 69A

above assessed income includes various additions amounting in all to Rs.34,93,920/- on account of disallowance of agricultural income, unexplained money deposited during de monetisation u/s 69A, disallowance of business promotion expenses and disallowance on account of unsecured loan. 5. Being aggrieved with the above assessment order, the assessee

Archana Muralidhar Bhandwalkar, Pune vs. Income Tax Officer Ward 5(2), Pune

In the result, appeal of the assessee is partly allowed

ITA 1840/PUN/2025[2016-17]Status: DisposedITAT Pune28 Nov 2025AY 2016-17
Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 271(1)(c)Section 56(2)(vii)Section 69A

proper relief. 4. The Id CIT(A) erred in law and on facts in confirming addition of Rs.21,50,000 us 69A as unexplained money u/s 69A when source for purchase of property was explained being Rs.18 lakhs representing loan taken from the financial institution and Rs.3.50 from internal saving

Archana Muralidhar Bhandwalkar, Pune vs. Income Tax Officer, Ward 5(2), Pune

In the result, appeal of the assessee is partly allowed

ITA 1615/PUN/2025[2016-17]Status: DisposedITAT Pune28 Nov 2025AY 2016-17

Bench: DR. DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 14Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 271(1)(c)Section 56(2)(vii)

proper relief. 4. The Id CIT(A) erred in law and on facts in confirming addition of Rs.21,50,000 us 69A as unexplained money u/s 69A when source for purchase of property was explained being Rs. 18 lakhs representing loan taken from the financial institution and Rs. 3.50 from

ITO, Nashik vs. Ankit Naresh Tulsian, Nashik

In the result, appeal of the Revenue is dismissed

ITA 2233/PUN/2024[2014]Status: DisposedITAT Pune28 Nov 2025

Bench: Shri Manish Borad & Shri Vinay Bhamore

Section 10(38)Section 115BSection 131Section 132Section 133ASection 144Section 147Section 148Section 250Section 69A

Naresh Tulsian) 21,00,08,500/ on account of long-term capital gains (LTCG) from the sale of 200,000 shares of MISHKAFIN as unexplained money under section 69A of the Income Tax Act, 1961, and taxing it under section 115BBE of the Income Tax Act, 1961. 2. Whether ... other financial criteria, concluded that LTCG claimed by the assessee u/s. 10(38) of the Act is bogus and made addition on account of unexplained money u/s. 69A of ITA.No.2233/PUN./ 2024 (Ankit Naresh Tulsian) the Act at Rs. 1,00,08,500/- and assessed the income

Spa Constructions, Hyderabad vs. ITO, Ward-8(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1132/HYD/2025[2017-18]Status: DisposedITAT Hyderabad28 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1132/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Spa Constructions Vs. Income Tax Officer Hyderabad Ward 8(1) Pan:Adffs5436E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Rama Rao राज" व "ारा/Revenue By:: Shri Ranjan Agrawala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 20/11/2025 घोषणा की तारीख/Pronouncement: 28/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Spa Constructions (“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 14.06.2025 For The A.Y 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate S. Rama RaoFor Respondent: : Shri Ranjan Agrawala, Sr. DR
Section 115BSection 143(2)Section 143(3)Section 69A

submissions, the Ld. AO held that the assessee failed to satisfactorily explain the capital introduced by the partners and treated the same as unexplained money under section 69A of the Act, read with section 115BBE of the Act. Assessment was completed by Ld. AO under section

Deputy Commissioner of Income Tax, Central Circle 3, Coimbatore vs. Auathan Ramesh Kumar, Coimbatore

In the result, both the appeals filed by the Revenue are dismissed

ITA 2399/CHNY/2025[2016-17]Status: DisposedITAT Chennai28 Nov 2025AY 2016-17

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. T. Mythili, JCITFor Respondent: Shri N. Arjun Raj, Advocate
Section 143(2)Section 250Section 69A

verify the deposits and work out the peak credit on the same and allow it for the purposes of computation of unexplained money by not appreciating that for getting the benefit of peak credit, the assessee has to admit that, borrowings made by the assessee from cash creditors are borrowings ... money was collected back, the date of such collection and the mode of collection, etc. Accordingly, the entire cash deposits were added as unexplained money u/s.69A of the Act and assessments were completed for assessment years 2015-16 & 2016-17. 4. Aggrieved by the assessments completed for assessment years

Deputy Commissioner of Income Tax, Central Circle 3, Coimbatore vs. Auathan Ramesh Kumar, Coimbatore

In the result, both the appeals filed by the Revenue are dismissed

ITA 2397/CHNY/2025[2015-16]Status: DisposedITAT Chennai28 Nov 2025AY 2015-16

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. T. Mythili, JCITFor Respondent: Shri N. Arjun Raj, Advocate
Section 143(2)Section 250Section 69A

verify the deposits and work out the peak credit on the same and allow it for the purposes of computation of unexplained money by not appreciating that for getting the benefit of peak credit, the assessee has to admit that, borrowings made by the assessee from cash creditors are borrowings ... money was collected back, the date of such collection and the mode of collection, etc. Accordingly, the entire cash deposits were added as unexplained money u/s.69A of the Act and assessments were completed for assessment years 2015-16 & 2016-17. 4. Aggrieved by the assessments completed for assessment years

Channapatna Siddappaji Sandeep Gowda, Channapatna vs. Income Tax Officer, Ward-1, Ramanagara

In the result appeal of the assessee is hereby allowed

ITA 1595/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Nov 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Bhuvan M, CAFor Respondent: Shri Shivanand H Kalakeri, CIT
Section 132Section 132(4)Section 153ASection 44ASection 69A

that the cash deposits were unexplained. Therefore, the AO treated the . ITA No.1593-1595/Bang/2025 Page 5 of 12 amount of Rs. 67,00,000/- as unexplained money under section 69A of the Act. The AO applied tax at special rates under section 115BBE of the Act. Further, the AO also noted ... section 153A of the Act. Once the AO has accepted business activity, the cash deposits must be treated as business receipts and not as unexplained money without having any cogent materials. . ITA No.1593-1595/Bang/2025 Page 6 of 12 9.1 The learned AR submitted that the cash deposits in the bank accounts

Channapatna Siddappaji Sandeep Gowda, Channapatna vs. Income Tax Officer, Ward-1, Ramanagara

In the result appeal of the assessee is hereby allowed

ITA 1594/BANG/2025[2016-17]Status: DisposedITAT Bangalore28 Nov 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Bhuvan M, CAFor Respondent: Shri Shivanand H Kalakeri, CIT
Section 132Section 132(4)Section 153ASection 44ASection 69A

that the cash deposits were unexplained. Therefore, the AO treated the . ITA No.1593-1595/Bang/2025 Page 5 of 12 amount of Rs. 67,00,000/- as unexplained money under section 69A of the Act. The AO applied tax at special rates under section 115BBE of the Act. Further, the AO also noted ... section 153A of the Act. Once the AO has accepted business activity, the cash deposits must be treated as business receipts and not as unexplained money without having any cogent materials. . ITA No.1593-1595/Bang/2025 Page 6 of 12 9.1 The learned AR submitted that the cash deposits in the bank accounts

Channapatna Siddappaji Sandeep Gowda, Channaptna vs. Income Tax Officer, Ward-1, Ramanagara

In the result appeal of the assessee is hereby allowed

ITA 1593/BANG/2025[2015-16]Status: DisposedITAT Bangalore28 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Bhuvan M, CAFor Respondent: Shri Shivanand H Kalakeri, CIT
Section 132Section 132(4)Section 153ASection 44ASection 69A

that the cash deposits were unexplained. Therefore, the AO treated the . ITA No.1593-1595/Bang/2025 Page 5 of 12 amount of Rs. 67,00,000/- as unexplained money under section 69A of the Act. The AO applied tax at special rates under section 115BBE of the Act. Further, the AO also noted ... section 153A of the Act. Once the AO has accepted business activity, the cash deposits must be treated as business receipts and not as unexplained money without having any cogent materials. . ITA No.1593-1595/Bang/2025 Page 6 of 12 9.1 The learned AR submitted that the cash deposits in the bank accounts

Vikram Babulal Shah, Mumbai vs. ITO, Assessment Unit It Department, Mumbai

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

ITA 917/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Nov 2025AY 2012-13

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhanvikram Babulal Shah Vs. Ito Assessment Unit It 3Rd Floor, R. No. 73, Shreenathji Department Bldg, Gulalwadi 142, Kika Street, Piramal Chambers Mumbai- Maharashtra-400 004 400 012 Pan: Cdops4473E (Appellant) (Respondent)

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 44ASection 68Section 69A

Vikram Babulal Shah 2012-13, wherein addition of Rs. 35,74,380/- made by the AO u/s 69A of the Act as unexplained money was confirmed. 2. The brief facts as culled out from the proceedings of authorities below are that the assessee filed the return of income ... conduct, is not entitled to further opportunities to prove his business income allegedly deposited in his bank account which has been considered as unexplained money. 13. We have considered the rival submissions and examined the record. We have noticed that assessee has given the details of 7 parties

Income Tax Officer, Mumbai vs. Wasundhara Vinay Joshi, Powai

In the result, the appeal of the Revenue is dismissed

ITA 5907/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Nov 2025AY 2016-17

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2016-17 Income Tax Officer, Wasundhara Vinay Joshi, Room No. 830D, C-111, Sunrise Apts., 8Th Floor, Vs. Raheja Vihar, Kautilya Bhavan, Chandivali Farm Road, Bandra Kurla Complex, Chandivali, Bandra East, Mumbai-400007. Mumbai-400051. Pan : Afjpk0008C (Appellant) (Respondent) For Assessee : Shri Chetan Shinde For Revenue : Shri G.J. Ninawe, Sr.Dr Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 18-08-2025, Pertaining To Assessment Year (Ay) 2016-17, Wherein The Revenue Has Taken The Following Grounds Of Appeal: "1) Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 1,76,860/- U/S 69A Of The Income Tax Act, 1961 Without Considering The Fact That The Assessee Fail To Furnish Demat Account & Copy Of Bank Statement.

For Appellant: Shri Chetan ShindeFor Respondent: Shri G.J. Ninawe, Sr.DR
Section 139Section 147Section 148Section 69A

proceeded to add a sum of Rs. 1,76,860/- under Section 69A of the Income-tax Act, 1961, treating the same as unexplained money. The reasons recorded by the assessing officer, however, are cryptic and internally inconsistent. Vide page 3 of the assessment order, it is noted that

K.P. Enterprise, Mumbai vs. Income Tax Officer -4(1), Mumbai

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

ITA 4646/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Nov 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosainkp Enterprises Vs. Ito, Ward 4(1) Shop No. 55, Hs Desai Ashar It Park, 6Th Compound, Shirsad, Floor, Road No. 16Z, Vajreshwari Road, Vasai (E) Wagle Industrial 401208. Estate, Thane (E). Pan/Gir No. Aakfk5524D (Applicant) (Respondent)

Section 250Section 5

produced before us requires verifications and are relevant piece of evidence to counter the allegation of revenue to treat the cash deposit as unexplained money u/s 69A of the Act and therefore I am of the view that one more opportunity be given to the assessee to represent his case