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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

Muraleedharan Pillai Arunkumar, Kollam vs. ITO Ward 1 & Tps, Alappuzha

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

ITA 690/COCH/2025[2017-18]Status: DisposedITAT Cochin20 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Muraleedharan Pillai Arunkumar .......... Appellant Karuvazhathu House, Thevalakara P.O. Palickal, Karunagappally 690524 [Pan: Avjpa3922F] Vs. The Income Tax Officer, Wd-1&Tps, Alappuzha.......... Respondent Assessee By: Shri R. Krishnan, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 20.11.2025 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 30.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income For Ay 2017-18 Was Filed By The Appellant. Based On The Information That The Appellant Made Cash Deposits Of Rs. 1,65,98,650/- National Faceless Assessment Centre, Delhi (Hereinafter Called "The Ao") Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued On 30.03.2021. In 2 Muraleedharan Pillai Arunkumar Response To The Notice U/S. 148, The Appellant Filed Return Of Income On 29.11.2021 Disclosing Income Of Rs. 3,00,990/-. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 29.03.2022 Passes U/S. 147 R.W.S. 144B Of The Act At Total Income Of Rs. 30,70,746/-. While Doing So, The Ao Made Addition Of Cash Deposits Of Rs. 20,11,631/- S Unexplained Money Of The Appellant. The Ao Also Made Addition On Account Of Vendor Commission Of Rs. 7,58,125/-.

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 142(1)Section 147Section 148

total income of Rs. 30,70,746/-. While doing so, the AO made addition of cash deposits of Rs. 20,11,631/- s unexplained money of the appellant. The AO also made addition on account of vendor commission of Rs. 7,58,125/-. 3. Being aggrieved, an appeal was filed

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Ward One Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1742/PUN/2025[2014-15]Status: DisposedITAT Pune20 Nov 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

assessee at Rs.2,55,580/-. The above assessed income includes addition u/s 69A of the Act of Rs.2,28,68,119/- as unexplained money deposited in Shri Renukamata Multi State Urban Cooperative Credit Society Limited. 7. Being aggrieved with the above assessment order, the assessee preferred an appeal before

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1741/PUN/2025[2015-16]Status: DisposedITAT Pune20 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

assessee at Rs.2,55,580/-. The above assessed income includes addition u/s 69A of the Act of Rs.2,28,68,119/- as unexplained money deposited in Shri Renukamata Multi State Urban Cooperative Credit Society Limited. 7. Being aggrieved with the above assessment order, the assessee preferred an appeal before

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Ward One Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1740/PUN/2025[2016-17]Status: DisposedITAT Pune20 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

assessee at Rs.2,55,580/-. The above assessed income includes addition u/s 69A of the Act of Rs.2,28,68,119/- as unexplained money deposited in Shri Renukamata Multi State Urban Cooperative Credit Society Limited. 7. Being aggrieved with the above assessment order, the assessee preferred an appeal before

Yashwant Namdev Pawar, Sangli vs. Income Tax Officer, Ward One Sangli

In the result, the appeal filed by the assessee in ITA

ITA 1739/PUN/2025[2013-14]Status: DisposedITAT Pune20 Nov 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1739 To 1742/Pun/2025 िनधा"रण वष" / Assessment Years : 2013-14 To 2016-17 Yashwant Namdev Pawar, Vs. Ito, Ward-1, Sangli. At Post Navraswad Karnal, Karlal Dist Sangli, Sangli- 416416. Pan : Bkepp5877P Appellant Respondent Assessee By : Shri Umeshkumar M. Mali Revenue By : Shri Umesh Phade Date Of Hearing : 03.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Bench : The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 16.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2013-14 To 2016-17 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 4. First We Shall Take Up The Appeal Of The Assessee In Ita No.1739/Pun/2025 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Umeshkumar M. MaliFor Respondent: Shri Umesh Phade
Section 142(1)Section 147Section 148Section 153CSection 69A

assessee at Rs.2,55,580/-. The above assessed income includes addition u/s 69A of the Act of Rs.2,28,68,119/- as unexplained money deposited in Shri Renukamata Multi State Urban Cooperative Credit Society Limited. 7. Being aggrieved with the above assessment order, the assessee preferred an appeal before

Amli Mohammed Taj, Kurnool vs. DCIT, Central Circle-2, Guntur

ITA 397/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.397/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Amli Mohammed Taj, Vs. Dcit, Kurnool. Central Circle-2, Pan: Achpt2412N Guntur. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of 06/11/2025 Hearing: घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 04/04/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 154 Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 19/05/2023 For The Assessment Year 2018-19. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 115BSection 142(1)Section 143(2)Section 153ASection 154Section 69A

claim that the seized cash of Rs. 26,82,200/- was sourced from his aforesaid activity of crossword puzzles, held the same as his unexplained money under section 69A of the Act that, as observed by him in the assessment order was to be subjected to tax at the rates ... excluded the amount of Rs. 26,82,200/- from the Profit & Loss Account of the assessee for assessing the same separately as his unexplained money under section 69A of the Act. 7. Thereafter, the AO vide his order passed under section 153A r.w.s 144 of the Act, dated 28/09/2021 determined

Naippalli Chirayil Chandy Joseph, Alappuzha vs. ITO Ward 2, Alappuzha

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

ITA 748/COCH/2025[2015-16]Status: DisposedITAT Cochin19 Nov 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2015-16 Naippalli Chirayil Chandy Joseph .......... Appellant Naippallichirayil House, Edathua, Alappuzha [Pan: Anspj6746P] Vs. The Income Tax Officer, Ward-2, Alappuzha .......... Respondent Assessee By: Shri K. Balaji, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.11.2025 Date Of Pronouncement: 19.11.2025 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 18.08.2025 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Income For Ay 2015-16 Was Filed By The Appellant. Based On The Information That The Appellant Made Cash Deposits In Bank Account During The Previous Year Relevant To Ay 2015-16, Ao Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued On 07.04.2022 After Complying With The Procedures

For Appellant: Shri K. Balaji, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 147Section 148Section 148A

While doing so, the AO made addition of cash deposits in the bank account aggregating to Rs. 34,47,051/- as unexplained money of the appellant. The AO also made addition of interest income of Rs. 21,355/-. 3. Being aggrieved, an appeal was filed before the CIT(A) with

Krishnan Saravanan, Palakkad vs. ITO Ward 2, Palakkad

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

ITA 736/COCH/2025[2017-18]Status: DisposedITAT Cochin19 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Krishnan Saravanan .......... Appellant 13/344 Chullimada, Kanjikode, Palakkad [Pan: Djhps8419G] Vs. The Income Tax Officer, Wd-2, Palakkad .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.11.2025 Date Of Pronouncement: 19.11.2025 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 11.08.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Engaged In The Business Of Authorised Service Agent Of Muthoot Money Transfer & Oxigen Services (India) Pvt. Ltd. The Return Of Income For Ay 2017-18 Was Filed On 30.07.2017 Declaring Income Of Rs. 3,97,020/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward-2, Palakkad (Hereinafter Called "The Ao") Vide Order Dated 23.12.2019 Passed

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 69A

total income of Rs. 41,28,520/-. While doing so, the AO made addition of cash deposits in the bank account as unexplained money u/s. 69A of the Act rejecting the explanation of the appellant that the source of cash deposits are out of money collected from customers during demonetisation