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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

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 640/CHNY/2025[2012-13]Status: DisposedITAT Chennai25 Nov 2025AY 2012-13

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

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

ITA 639/CHNY/2025[2010-11]Status: DisposedITAT Chennai25 Nov 2025AY 2010-11

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 638/CHNY/2025[2009-10]Status: DisposedITAT Chennai25 Nov 2025AY 2009-10

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

Chenniappa Gounder Deivasigamani, Kangayam vs. Ward I(4) / Tirupur, Tirupur

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

ITA 2380/CHNY/2025[2017-18]Status: DisposedITAT Chennai25 Nov 2025AY 2017-18

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 2380/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Shri Chenniappa Gounder The Income Tax Officer, Deivasigamani, Vs. Ward 1(4), 565/4-A, Tirupur Sivamathy Modern Rice Mill, Agasthilingampalayam Road, Tiruppur – 638 701. Pan: Aenpd 8814L (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Harinandha Kumar, Ca (Through Virtual Mode) ""यथ" क" ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई क" तारीख/Date Of Hearing : 25.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.11.2025

For Appellant: Shri Harinandha Kumar, CAFor Respondent: Ms. T. Mythili, JCIT
Section 147Section 148Section 250Section 69A

addition u/s.69 or 69A of the Act. Because, the mandate of the provisions of Section 69 & 69A of the Act, i.e., unexplained investments and unexplained money etc., may be deemed to be the income of the assessee for the financial year relevant to assessment year concerned, in which the assessee

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. V N S Finance, Karur

In the result, the appeal of the Revenue stands allowed for statistical purposes

ITA 2292/CHNY/2024[2020-21]Status: DisposedITAT Chennai25 Nov 2025AY 2020-21

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Ms. Pushpa Hemachand, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate
Section 131Section 132Section 143(2)Section 143(3)

assessment u/s.143(3) of the Act on 30.09.2022. The entire amount of Rs.92,80,220/- found during the course of search was treated as unexplained money u/s.69A of the Act and assessed protectively in the hands of the assessee-firm. 9. Aggrieved by the assessment order, the assessee preferred ... pertaining to the availability and source of the cash balance and consequently treated the entire amount of physical cash of Rs.92,80,220/- as unexplained money u/s.69A of the Act. The addition :-6-: ITA. No:2292/Chny/2024 was made on a protective basis in the hands of the assessee-firm

Rakesh Jayantilal Shah, Mumbai vs. ITO 41(2)(4), Mumbai

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

ITA 3189/MUM/2025[2014-15]Status: DisposedITAT Mumbai25 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 131Section 250Section 68

placed upon the following judicial precedents: Sr. Citation Pronouncements no. 1. [2005] 142 Section 69A of the Income-tax Act, 1961 - TAXMAN 76 (NAG.) Unexplained money - Assessment year 1994-95 - (MAG.) Assessee had paid back certain loan which was ITAT NAGPUR considered to be beyond his means - While BENCH explaining

Rakesh Jayantilal Shah, Mumbai vs. ITO 41(2)(4), Mumbai

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

ITA 3188/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Nov 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 131Section 250Section 68

placed upon the following judicial precedents: Sr. Citation Pronouncements no. 1. [2005] 142 Section 69A of the Income-tax Act, 1961 - TAXMAN 76 (NAG.) Unexplained money - Assessment year 1994-95 - (MAG.) Assessee had paid back certain loan which was ITAT NAGPUR considered to be beyond his means - While BENCH explaining

Rakesh Jayantilal Shah, Mumbai vs. ITO 41(2)(4), Mumbai

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

ITA 3168/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Nov 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 131Section 250Section 68

placed upon the following judicial precedents: Sr. Citation Pronouncements no. 1. [2005] 142 Section 69A of the Income-tax Act, 1961 - TAXMAN 76 (NAG.) Unexplained money - Assessment year 1994-95 - (MAG.) Assessee had paid back certain loan which was ITAT NAGPUR considered to be beyond his means - While BENCH explaining

Rakesh Jayantilal Shah, Mumbai vs. 41(2)(4), Mumbai

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

ITA 3167/MUM/2025[2015-16]Status: DisposedITAT Mumbai25 Nov 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 131Section 250Section 68

placed upon the following judicial precedents: Sr. Citation Pronouncements no. 1. [2005] 142 Section 69A of the Income-tax Act, 1961 - TAXMAN 76 (NAG.) Unexplained money - Assessment year 1994-95 - (MAG.) Assessee had paid back certain loan which was ITAT NAGPUR considered to be beyond his means - While BENCH explaining

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 530/RJT/2025[2015-16]Status: DisposedITAT Rajkot24 Nov 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 527/RJT/2025[2015-16]Status: DisposedITAT Rajkot24 Nov 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 525/RJT/2025[2016-17]Status: DisposedITAT Rajkot24 Nov 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 518/RJT/2025[2015-16]Status: DisposedITAT Rajkot24 Nov 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

ITA 515/RJT/2025[2014-15]Status: DisposedITAT Rajkot24 Nov 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (निर्धारण वर्ष / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar, Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar - 361006 (Respondent) Pan No. - Aυτρκ7716N (Appellant) आयकर अपील सं./Ita No. 515,518,527&530/Rjt/2025 (निर्धारण वर्ष / Assessment Year: (2015-16) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar - 361006 (Respondent) Pan No. - Αυτρκ7716N (Appellant) आयकर अपील सं./Ita No. 513 & 514/Rjt/2025 (निर्धारण वर्ष / Assessment Year: (2014-15) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar - 361006 (Respondent) Pan No. - Aαυτρκ7716N (Appellant)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 514/RJT/2025[2015-16]Status: DisposedITAT Rajkot24 Nov 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 513/RJT/2025[2014-15]Status: DisposedITAT Rajkot24 Nov 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 512/RJT/2025[2013-14]Status: DisposedITAT Rajkot24 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 511/RJT/2025[2013-14]Status: DisposedITAT Rajkot24 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 510/RJT/2025[2013-14]Status: DisposedITAT Rajkot24 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

credits/deposits in the bank accounts of Rs. 1,58,64,799/- remains unexplained. Therefore, another show-cause notice, proposing to add the same as unexplained money u/s 69A of the Income Tax Act, 1961 was issued to assessee. In response, the assessee submitted its reply before the assessing officer. However ... remains unexplained and the same was added back, as the income of the assessee u/s 69A of the Income Tax Act, 1961, as unexplained money. The assessing officer also clarified that tax payable will be as per provision u/s115BBE of the Act, at maximum marginal rate @30% for the A.Y.2015-16

Rajesh Sivan, Ernakulam vs. Income Tax Officer, Ward 1 & Tps, Kannur

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

ITA 688/COCH/2025[2019-20]Status: DisposedITAT Cochin24 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Rajesh Sivan .......... Appellant Adhibhavan, Thrikkakara S.O., Ernakulam [Pan: Banps8167A] Vs. The Income Tax Officer, Wd-1 & Tps, Kannur .......... Respondent Assessee By: Shri Lukose Joseph, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 24.11.2025 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 18.07.2025 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Engaged In The Business Of Construction Of Residential Houses. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed For Ay 2019-20 By The Appellant. Based On The Information That The Appellant Had Made Deposits In Bank Of Baroda & Federal Bank Aggregating To Rs. 39,86,000/- , The Ao Issued A Notice U/S. 148 Of The Act, 1961 (The 2 Rajesh Sivan Act) 29.03.2023. In Response To Notice U/S. 148, The Appellant Filed Return Of Income On 28.04.2023 Declaring Total Income Of Rs. 6,12,020/-. Against The Said Return Of Income, The Assessment Was Completed By The Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 14.02.2024 Passed U/S. 147 R.W.S. 144B Of The Act At Total Income Of Rs. 45,98,020/-. While Doing So, The Ao Treated The Cash Deposits In The Bank Accounts Of Rs. 39,86,000/- As Unexplained Money Of The Appellant & Brought To Tax The Same.

For Appellant: Shri Lukose Joseph, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148

While doing so, the AO treated the cash deposits in the bank accounts of Rs. 39,86,000/- as unexplained money of the appellant and brought to tax the same. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action ... business receipts are duly accounts in the books of account and, therefore, the AO was not justified in treating the cash deposits as unexplained money of the appellant. It is further submitted that the appellant could not reply to the notices issued by the AO for the reason that