“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

Mahalakshmi Sanagala, Vuyyuru vs. Inome Tax Officer, Ward-1, Gudiwada

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

ITA 427/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble

Section 133(6)Section 142(1)Section 147Section 148Section 250

bank and determined the income of the assessee at Rs.13,93,450/- by making addition of cash deposits of Rs.8,00,000/- as unexplained money under section 69A of the Act. 7. On being aggrieved by the addition made by the Ld. AO, assessee filed an appeal before

Ajithkumar Singu, Guntur vs. Income Tax Officer, Ward (International Taxation), Vijayawada

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

ITA 348/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2021-22

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.348/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2021-22) Vs. Ajithkumar Singu The Income Tax Officer Ward (International Taxation) D.No. 8-76-1, Murikipudi Income Tax Office Chilakaluripeta C.R. Building, Annex Ramachandrapuram M.G. Road Guntur – 522626 Vijayawada – 520002 Andhra Pradesh Andhra Pradesh [Pan: Etxps2554D]

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 69A

satisfied with the explanation by the assessee, Ld. AO proposing an addition of Rs.1,76,84,000/- under section 69A of the Act as unexplained money issued show-cause notice to the assessee to file his objections. Assessee furnished his reply on 26.12.2022. The Ld.AO observed that there ... withdrawals through exchange and cash deposited, delay in depositing the cash and exchanging money, and accordingly proceeded to add Rs.1,76,84,000/- as unexplained money under section 69A of the Act. Further, Ld. AO also treated a net agricultural income of Rs.3,50,000/- as income from other sources

Gujarat State Agriculture Marketing Board, Gandhinagar vs. The ITO, Ward-1, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 1317/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Nov 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble

For Appellant: Shri Alpesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 10Section 10(20)Section 139Section 147Section 250Section 69A

making addition of Rs.38,57,519/-. Total addition of Rs.38,57,519/-made by adopting the interest amount from 26AS and treated it as unexplained money. ITA Nos. 1316 & 1317/Ahd/2025 – Gujarat State Agriculture Mktg Board Vs. ITO Asst. Year : 2016-17 & 2017-18 - 2– 2. The learned A.O. has erred

Gujarat State Agriculture Marketing Board, Gandhinagar vs. The ITO, Ward-1, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 1316/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad26 Nov 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble

For Appellant: Shri Alpesh Shah, ARFor Respondent: Shri Abhijit, Sr DR

Section 10Section 10(20)Section 139Section 147Section 250Section 69A

Kondal Reddy Anumula, Hyderabad vs. ACIT., Central Circle - 1(2), Hyderabad

In the result, the appeal of assessee in ITA No

ITA 286/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

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

Ground Nos. 2 and 3 of the assessee’s appeal is addition of Rs. 80,00,000/- under Section 69A of the Act as unexplained money towards Gift given to Smt. Geetha Sudini (Sister-in-law of the assessee). The A.O. made addition towards Rs. 80,00,000/- under Section ... opening bank balance available, which was carried forward from the previous financial years and therefore, the additions made by the A.O. towards unexplained money under Section 69A of the Act cannot be sustained. Therefore, he submitted that the additions made by the A.O. should be deleted. 27. The learned Senior

Kondal Reddy Anumula, Hyderabad vs. ACIT., Central Circle - 1(2), Hyderabad

In the result, the appeal of assessee in ITA No

ITA 285/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Nov 2025AY 2015-16

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

Kondal Reddy Anumula, Hyderabad vs. ACIT., Central Circle- 1(2), Hyderabad

In the result, the appeal of assessee in ITA No

ITA 284/HYD/2025[2013-14]Status: DisposedITAT Hyderabad26 Nov 2025AY 2013-14

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

Bhupal Infrastructure Private Limited, Hyderabad vs. ACIT., Central Circle -1(2), Hyderabad

In the result, the appeal of the assessee for A

ITA 282/HYD/2025[2019-20]Status: DisposedITAT Hyderabad26 Nov 2025AY 2019-20

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

seized during the course of search. Therefore, the A.O. made addition of Rs. 4,00,000/- under Section 69A of the Act as unexplained money. On appeal, the Ld. CIT(A) confirmed the addition. 45. The learned counsel for the assessee submitted that, the Ld. CIT(A) erred in sustaining

Bhupal Infrastructure Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee for A

ITA 281/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

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

Bhupal Infrastructure Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee for A

ITA 280/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

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

Nemi Chand, Gudur vs. ITO., Ward-1, Gudur

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 1288/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1288/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Nemi Chand, Vs. Income Tax Officer, 1-2-8/11A, 302, 3Rd Floor, Ward-1, Srinivas Street No.1, Guduru. Himayat Nagar, Hyderabad, Telangana. Pan: Achpr2242L (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Sridhar Jhawar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 13/06/2025 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 23/04/2021 For The Assessment Year 2018-19. The Assessee Has 2 Nemi Chand Vs. Ito Assailed The Impugned Order On The Following Grounds Of Appeal Before Us: 1. “Whether On The Facts & Circumstances Of The Case & In Law Whether The Order Of The Learned Commissioner Of Income Tax Was Pervasive In Considering The Income From Capital Gains As Business Income In Terms Of Provisions Of Section 2(14) Read With Section 2(47) 2. Whether On The Facts & Circumstances Of The Case & In Law. Whare Capital Gain Was Invested In Purchase/Construction Of Residential House Within Time Limit Prescribed Under Section 2 54(1), Assessment Order Allowing Assesses Claim Under Section 54 Could Not Be Treated As Erroneous & Prejudicial To Interest Of Revenue Only Because Capital Gain Was Not Deposited In Capital Gain Account Scheme. 3. Any Other Ground (If Any) That May Be Urged At The Time Of Hearing.”

For Appellant: Sri Sridhar Jhawar, CAFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 143(3)Section 2Section 2(14)Section 2(47)Section 54

therefore, the AO held the entire amount of consideration of Rs. 36,17,648/-, i.e., the sale consideration received by the assessee as his unexplained money under section 69A of the Act. 7. Alternatively, the AO observed that as the assessee along with certain other land owners had joined hands ... falling to the share of the assessee of Rs. 36,17,648/- as 7 Nemi Chand vs. ITO having been sourced out of his unexplained money under section 69A of the Act, determined his income at Rs. 63,38,988/-. 9. Aggrieved, the assessee carried the matter in appeal before

Abdul Kani Kareem, Chennai vs. ITO, Ncw-22(1), Tambaram

In the result, appeal filed by the assessee is allowed

ITA 1905/CHNY/2025[2016-17]Status: DisposedITAT Chennai26 Nov 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: 18.11.2025

Section 147Section 148Section 148ASection 151ASection 69A

Delhi dated 12.03.2024 u/s.147 r.w.s 144B of the Act by making an addition of cash deposits to the tune of Rs.63,15,769/- as unexplained money u/s.69A of the Act and the assessment for the A.Y.2016-17 was completed by the Assessment Unit of NFAC, Delhi dated 11.03.2024 u/s.147 r.w.s 144B ... making an addition of cash deposits to the tune of Rs.90,80,110/- as unexplained money u/s.69A of the Act. Aggrieved by the order of the AO, the assessee filed appeal before the ld.CIT(A) and the same was confirmed by the ld.CIT(A) in the impugned order. 6. Aggrieved

Abdul Kani Kareem, Chennai vs. ITO, Ncw-22(1), Tambaram

In the result, appeal filed by the assessee is allowed

ITA 1904/CHNY/2025[2015-16]Status: DisposedITAT Chennai26 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: 18.11.2025

Section 147Section 148Section 148ASection 151ASection 69A

Mr. Bhausaheb B Pansare, Kalyan vs. ITO Ward-3(1), Kalyan

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

ITA 5931/MUM/2025[2023-24]Status: DisposedITAT Mumbai26 Nov 2025AY 2023-24

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2023-24

For Respondent: Shri Madhur Agarwal

Section 69C

credit cards were treated as unexplained, and the same were credit cards were treated as unexplained, and the same were brought to tax as unexplained money under the provisions of brought to tax as unexplained money under the provisions of brought to tax as unexplained money under the provisions

Mohd. Sharfuddin, Moradabad vs. ITO 1(1), Moradabad

In the result, appeal of assessee in ITA No

ITA 4909/DEL/2025[2017-18]Status: DisposedITAT Delhi26 Nov 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 144Section 145(3)Section 69A

counsel for the assessee that the Assessing Officer could not substantiate his view that how the cash deposit of the assessee is unexplained money and the assessee has earned extra income other than the disclosed in his financial statements. The Assessing Officer has no material and valid reason

Madan Lal Sharma, Bikaner vs. ITO, Ward, Nokha

In the result, the appeal of the assessee is allowed

ITA 309/JODH/2025[2017-18]Status: DisposedITAT Jodhpur25 Nov 2025AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon'Ble & Dr. S. Seethalakshmi, Hon'Ble

Section 115BSection 144Section 234ASection 69A

that the CIT(A)'s decision is illegal in sustaining addition of 10,66,638/- in respect of cash deposits in bank account as unexplained money u/s 69A of the Act. 3. Having heard both the sides and perusal of record, we find that appellant assessee has made a cash ... appellant argued that the CIT(A)/NFAC has sustained addition of Rs 10,66,638/- in respect of cash deposits in bank account as unexplained money u/s 69A of the act in arbitrary manner rejecting source of aforesaid cash deposits in bank account which was duly supported with credible evidence

Hothi Samat Keshwala, Porbandar vs. Income Tax Office, Ward 2(4), Porbandar

In the result, the appeal filed by the assessee is partly allowed in above terms

ITA 408/RJT/2025[2017-18]Status: DisposedITAT Rajkot25 Nov 2025AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 408/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Hothi Samat Keshwala Ito, Wd – 2(4), At Visavada, Via Bokhira Porbandar, Vs. Income Tax Office, Nh-8E, Porbanadar – 360575 Porbandar Road, Porbandar-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Buppk0380P (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 02/09/2025 : 25/11/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 05.08.2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Vide Order 21.10.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 250Section 5

demonetarization period and remaining cash deposits of Rs. 18,00,000/-( Rs. 18,23,500- Rs. 23,500) was treated as the assessee's unexplained money and taxed in the hand of the assessee u/s 69A of the I.T. Act. 8. Aggrieved by the order of the assessing officer

M.A. Financial Services Pvt. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

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

ITA 1273/KOL/2025[2018-2019]Status: DisposedITAT Kolkata25 Nov 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 148Section 148ASection 151ASection 250

case the action of the Ld. CIT(A) to uphold the action of the AO in making addition of Rs.2,10,18,000/-as unexplained money on account of consideration received for sale of shares is contrary to the material evidences on record and the addition is arbitrary. excessive, illegal

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

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

ITA 642/CHNY/2025[2014-15]Status: DisposedITAT Chennai25 Nov 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.638, 639, 640, 641 & 642/Chny/2025 िनधा?रण वष? /Assessment Years: 2009-10, 2010-11, 2012-13, 2013-14 & 2014-15 Singvi Lickmi Chand, The Dy. Commissioner Of No.3, Kasi Chetty Street, Vs. Income Tax, Ambur – 635 803. Central Circle-3(3), Pan: Aaapl 6736A Chennai.

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A

deleted. 5. The learned CIT(A)-20 ought to have seen that the AO erred in making an addition under the head unexplained money based on mere presumptions and suspicions without any direct material to establish that the amounts in the employee passbooks were unaccounted income of the appellant

Shri Singhvi Lickmi Chand, Ambur vs. DCIT, Central Circle-3(3), Chennai

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

ITA 641/CHNY/2025[2013-14]Status: DisposedITAT Chennai25 Nov 2025AY 2013-14

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Bipin C.N, CIT

Section 153ASection 69A