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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

Sonu Agarwal, Jaipur vs. Income Tax Officer Ward 1(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1263/JPR/2025[2016-2017]Status: DisposedITAT Jaipur19 Nov 2025AY 2016-2017

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Gaurav Awasthi, JCIT
Section 10(38)Section 139Section 147Section 148Section 148ASection 250

making addition of Rs. 81,84,838/- under section 69A read with section 115BBE of the IT Act, 1961 on account of unexplained money, vide his order dated 29.05.2023. Being aggrieved by the assessment order, the assessee preferred appeal before the ld. CIT (A). The ld. CIT (A) after discussing

Saugaat, Ambala Cantt vs. ITO, Ward 4, Ambala Cantt. (Assessment Unit), Ambala Cantt

ITA 443/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh19 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Vineet Krishan, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR
Section 133(6)Section 147Section 148Section 249(4)Section 250Section 68Section 69A

Income Tax (Appeals) gravelly erred in upholding the action of the Id. Assessing Officer who had made addition of Rs. 2,08,023/-as unexplained money under Section 69A of the Income Tax Act, 1961 whereas the same pertain to Sh. Hemant Batra proprietor of M/s Saugaat

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

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

ITA 1352/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Nov 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

LTCG of Rs.28,61,127 to the Appellant under section 10(38) of the Income Tax Act, and bringing the LTCG to tax as unexplained money under section 69A of the Act. The Ld.NFAC failed to appreciate the facts, evidences filed by the Appellant, and the evidences available on record ... form of bogus Long Term Capital Gains. Therefore, by considering certain judicial precedents, rejected the explanation of the assessee and treated sale consideration unexplained money and brought to tax u/s 69A of the Act. 6. Aggrieved by the assessment order, the assessee preferred appeal before

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

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

ITA 1351/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Nov 2025AY 2016-17

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

LTCG of Rs.28,61,127 to the Appellant under section 10(38) of the Income Tax Act, and bringing the LTCG to tax as unexplained money under section 69A of the Act. The Ld.NFAC failed to appreciate the facts, evidences filed by the Appellant, and the evidences available on record ... form of bogus Long Term Capital Gains. Therefore, by considering certain judicial precedents, rejected the explanation of the assessee and treated sale consideration unexplained money and brought to tax u/s 69A of the Act. 6. Aggrieved by the assessment order, the assessee preferred appeal before

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

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

ITA 1349/HYD/2025[2014-15]Status: DisposedITAT Hyderabad19 Nov 2025AY 2014-15

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

LTCG of Rs.28,61,127 to the Appellant under section 10(38) of the Income Tax Act, and bringing the LTCG to tax as unexplained money under section 69A of the Act. The Ld.NFAC failed to appreciate the facts, evidences filed by the Appellant, and the evidences available on record ... form of bogus Long Term Capital Gains. Therefore, by considering certain judicial precedents, rejected the explanation of the assessee and treated sale consideration unexplained money and brought to tax u/s 69A of the Act. 6. Aggrieved by the assessment order, the assessee preferred appeal before

Sudhir Babu Chalasani, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

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

ITA 1348/HYD/2025[2013-14]Status: DisposedITAT Hyderabad19 Nov 2025AY 2013-14

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 10(38)Section 69A

LTCG of Rs.28,61,127 to the Appellant under section 10(38) of the Income Tax Act, and bringing the LTCG to tax as unexplained money under section 69A of the Act. The Ld.NFAC failed to appreciate the facts, evidences filed by the Appellant, and the evidences available on record ... form of bogus Long Term Capital Gains. Therefore, by considering certain judicial precedents, rejected the explanation of the assessee and treated sale consideration unexplained money and brought to tax u/s 69A of the Act. 6. Aggrieved by the assessment order, the assessee preferred appeal before

Jayanta Fanzen Lighting Industries Private Limited, Kolkata West Bengal vs. Assistant Commissioner of Income Tax, Circle 10(1), Kolkata

In the result, the appeal of the assessee

ITA 1239/KOL/2025[2017-18]Status: DisposedITAT Kolkata19 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Jayanta Fanzen Lighting Acit, Circle 10(1) Industries Private Limited Aayakar Bhawan P-7, 2F Destiny Tower, 2 Nd Floor, Chowringhee Square, Vs. Chinar Park, Barabazar, Kolkata-700069, West Bengal Kolkata-700007, West Bengal (Appellant) (Respondent) Pan No. Aabcj6752E Assessee By : Shri Giridhar Dhelia, Ar Revenue By : Shri Dipu Koley, Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri Giridhar Dhelia, ARFor Respondent: Shri Dipu Koley, DR
Section 143(2)Section 69A

respond to the various notices issued by the ld. AO, the amount of cash deposited into the bank account was treated as unexplained money u/s 69Aof the Act and added to the income of the assessee in the assessment framed. 04. Thereafter, the assessee challenged the order before ... cash deposited during the year including the cash deposited of ₹35,80,000/- during demonetization period was treated by the ld. AO as unexplained money u/s 69A of the Act. We note that during the appellate proceedings, the assessee furnished before the ld. CIT (A) Jayanta Fanzen Lighting Industries Private

Mr. Mohamed Iqbal, Nagapattinam vs. ITO, Ward-1, Nagapattinam

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

ITA 2392/CHNY/2025[2015-16]Status: DisposedITAT Chennai19 Nov 2025AY 2015-16

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

For Appellant: Shri Shrenik Chordia, C.AFor Respondent: Mr. Krishna Murthy AT, JCIT
Section 143(3)Section 147Section 148

receipt of Rs.4,00,000/-. On perusal of the documents submitted by the assessee, the AO made an addition of Rs.18,00,000/- as unexplained money for non-furnishing of Capital Gain details and concluded the assessment proceedings u/s.143(3) r.w.s 147 of the Act dated 28.03.2024. 3. Aggrieved

Narayanan Varalakshmi, Madurai vs. ITO, Ncw-1(5), Madurai

In the result, appeal filed by the assessee is allowed

ITA 2382/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Nov 2025AY 2018-19

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

For Appellant: Mr. Krishna Murthy AT, J.C.I.TFor Respondent: 23.10.2025
Section 147Section 148Section 148ASection 151ASection 69A

Delhi dated 25.03.2023 u/s.147 r.w.s 144B of the Act by making an addition of cash deposits to the tune of Rs.16,66,330/- 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

Jai Prakash Saini, Delhi vs. ITO, Delhi

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

ITA 3996/DEL/2025[2014-15]Status: DisposedITAT Delhi19 Nov 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2014-15] Jai Prakash Saini Vs Ito 4240, Arya Pura Sabzi Nfac, New Delhi Mandi, Roshanara Road, New Delhi-110007. Pan-Bbwps4100D Appellant Respondent Appellant By Shri Mohit Bansal, Ca Respondent By Ms. Rajinder Kaur, Cit Dr Date Of Hearing 19.11.2025 Date Of Pronouncement 19.11.2025

Section 142(1)Section 147Section 148Section 250Section 271(1)Section 69B

advance from IOCL Officers Welfare Society on account of sale of property. 4. That the Ld. AO has taxed Rs 17,04,000/- as unexplained money u/s 69B in respect of cash deposited in saving bank without considering the fact that entire credit cannot be income of assessee

Nidhi Jain, Gali No., Sbi Colony, Fafadih, Raipur vs. Assistant Commissioner of Income Tax, Circle-1(1), Raipur (C.G.), Civil Lines

ITA 659/RPR/2025[2013-14]Status: DisposedITAT Raipur18 Nov 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 659/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

For Appellant: None (adjournment application)For Respondent: Shri Ram Tiwari, CIT-DR
Section 144Section 147Section 148Section 249(3)Section 250Section 69A

after considering the information available on record. In conclusion, an addition of Rs. 7692594/- was made u/s 69A of the Act as unexplained money in the hands of assessee. 3. Being aggrieved, assessee filed an appeal before Ld. CIT(A) but remain unsuccessful as the appeal of assessee has been

Income Tax Officer, Raipur vs. Sanjay Kumar Punjabi, Raipur

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

ITA 565/RPR/2025[2019-20]Status: DisposedITAT Raipur18 Nov 2025AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.565/Rpr/2025 िनधा"रण वष" /Assessment Year: 2019-20 Income Tax Officer, Central Revenue Building, Civil Lines, Raipur, Chhattisgarh, 492001 .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Mr. Sanjay Kumar PunjabiFor Respondent: Dr. Priyanka Patel, Sr.DR
Section 139(1)Section 147Section 148Section 69ASection 80G

making addition of Rs.3,00,000/- regarding disallowance of claim u/s 80GGC and 3 Income Tax Officer Vs. Sanjay Kumar Punjabi Rs.73,513/- as unexplained money u/s 69A r.w.s. 115BBE of the Act. Penalty proceedings were separately initiated against the assessee. In this regard, there was no compliance ... that there were no compliance by the assessee at the first appellate stage regarding both the issues: (i) exemption claimed u/s 80GGC and (ii) unexplained money u/s 69A of the Act. The assessee submits that it is not denied that reasonable opportunities were provided, however, he was prevented from reasons

Bhavin Girishbhai Shah, Bhavnagar vs. NFAC, Delhi Present Jurisdiction- the Dy.CIT, Circle-1(1), Bhavnagar

The appeal of the assessee is allowed for statistical purposes

ITA 1378/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad18 Nov 2025AY 2022-23

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

For Appellant: Shri Vartik Choksi, A.RFor Respondent: Shri Abhijit, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 69

Sumeru Buildcon and Lucky Steel, routed through the bank and sweep accounts, were not recorded in the books of account and therefore represented unexplained money or unexplained cash credit in the hands of the assessee. 18. On a careful consideration of the material placed before us, it emerges from

Deepak Vasant Marane, Pune vs. Income Tax Officer Ward 6(3), Pune

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

ITA 2081/PUN/2025[2020-21]Status: DisposedITAT Pune18 Nov 2025AY 2020-21

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.2081/Pun/2025 निर्धारण वर्ा /Assessment Year: 2020-21 Deepak Vasant Marane, Ito, Ward-6(3), Pune Plot No. 84 Ganpati Nagar, Taloda Road, Nandurbar-425412 Vs. Maharashtra Pan-Ahjpm4976D अपीलधर्थी / Appellant प्रत्यर्थी/Respondent

For Appellant: Shri Sandeep Lodha (throughFor Respondent: Shri
Section 147Section 148Section 148BSection 151Section 250Section 69Section 69A

invoking provisions of Sec. 69A of the Income Tax Act 1961 being the cash deposits in bank is treated as unexplained money, for reasons stated in the impugned order or otherwise. 6.The Appellant craves leaves to alter, amend withdraw or substitute any ground or grounds

M/S. Shroff Tradelink Pvt. Ltd., Kolkata vs. ITO, Ward 1(1), Kolkata

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 1017/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Nov 2025AY 2015-2016
Section 144Section 147Section 148Section 148ASection 251(1)(a)Section 69A

accept the explanation and completed the assessment under Section 147 read with Section 144 of the Act by treating ₹ 25 lakh as unexplained money under Section 69A and assessed the total income at ₹ 25,13,160/-. M/s Shroff Tradelink Pvt. Ltd. 3. The assessee preferred appeal before

M/S. Shroff Tradelink Pvt. Ltd., Kolkata vs. ITO, Ward 1(1), Kolkata

In the result, both appeals filed by the assessee are allowed for statistical purposes

ITA 1016/KOL/2025[2014-2015]Status: DisposedITAT Kolkata18 Nov 2025AY 2014-2015

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 144Section 147Section 148Section 148ASection 251(1)(a)Section 69A

accept the explanation and completed the assessment under Section 147 read with Section 144 of the Act by treating ₹ 25 lakh as unexplained money under Section 69A and assessed the total income at ₹ 25,13,160/-. M/s Shroff Tradelink Pvt. Ltd. 3. The assessee preferred appeal before

Abani Ranjan Maity, Mumbai vs. Ward 20(1)(1, Mumbai

In the result, appeal is allowed for statistical purposes

ITA 5590/MUM/2025[2013-14]Status: DisposedITAT Mumbai18 Nov 2025AY 2013-14

Bench: Shri Saktijit Dey & Ms. Padmavathy Smr Abani Ranjan Maity, Income Tax Officer, 301, Lucky Star Bldg., Ward 20(1)(1), Jerbai Wadia Road, Parel, Piramal Chambers, Vs. Mumbai-400012 Lalbaugh, Mumbai - 400012 (Appellant) : (Respondent) Pan No. Awnpm 4623L Appellant By : Shri Rajesh C. Dali Respondent By : Shri Surendra Mohan, Sr. Dr (Appellant) (Respondent) Date Of Hearing : 18.11.2025 Date Of Pronouncement : 18.11.2025

For Appellant: Shri Rajesh C. DaliFor Respondent: Shri Surendra Mohan, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 69Section 69A

made cash deposits in bank account aggregating to Rs.44,95,000/-. By treating these amounts as unexplained investment u/s. 69 of the Act and unexplained money u/s. 69A of the Act, respectively, the AO added back to the income of the assessee. 4. Assessee contested the aforesaid additions

Narendra Shantilal Bapna, Navi Mumbai vs. Income Tax Officer, WD-28(2)(3), Mumbai

In the result, appeal filed by the assessee stands allowed

ITA 4198/MUM/2025[2014-15]Status: DisposedITAT Mumbai18 Nov 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarnarendra Shantilal Bapna V/S. Income Tax Officer, Ward – Flat No. A2501, Plot No. R3 बनाम 28(2)(3) B Emerald Bay, Sector 14, 4Th Floor, Tower No. 6, Vashi Nerul, Navi Mumbai – Station Complex, Vashi, Navi 400 706, Maharashtra Mumbai– 400703, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aclpb8458J Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri Leyaqat Ali Aafaqui, (Sr.DR)
Section 131Section 143(3)Section 68

СТО (154 ITR 148).It concluded that the funds amounting to Rs. 2,33,24,050/- which was the assessee's own unexplained money, were introduced in the form of LTCG of Rs. 2,22,79,435/- through a colorable device under a pre-meditated and well planned strategy. Before

Jamir Ali, Kumarghat vs. Commissioner of Income Tax (Appeals), Delhi

Appeal is allowed for statistical purposes

ITA 60/GTY/2025[2017-18]Status: DisposedITAT Guwahati17 Nov 2025AY 2017-18

Bench: Him. The Ld. Cit(A) Has Given The Following Findings:

Section 115BSection 250Section 271ASection 69A

simplified explanation of Section 271AAC(1), an Assessing Officer can impose a penalty only if the taxpayer's income includes certain unexplained money or investments falling under Sections 69A, 2 698, 69C, or 68 of the Act. In this case, the Ld. Commissioner R (Appeals) passed his order under Section

Reva Enterprise, Narmada vs. Income Tax Officer, Ward 2(1), Bharuch

In the result, ITA No.259/SRT/2024 is partly allowed, ITA No

ITA 414/SRT/2024[2017-18]Status: DisposedITAT Surat17 Nov 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.259, 380 & 414/Srt/2024 Assessment Years: (2017-18) (Hybrid Hearing) Reva Enterprises, बनाम/ Income Tax Officer, Vs. Plot No. 50, Gandhi Market, Ward – 2(4), Rajpipla Road, Ankleshwar, Bharuch Sarangpore, Narmada - 393001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aanfr8509E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रतीकीओरसे/Appellant By Shri Mehul Shah, Ca राज"कीओरसे /Respondent By Shri Ajay Uke (Sr. Dr) With Shri Kevin Langaliya, Ca सुनवाई की तारीख/Date Of Hearing 18/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 17/11/2025

Section 115BSection 131(1)(d)Section 133(6)Section 250Section 271ASection 271FSection 69A

core issue is addition of Rs.82,92,950/- by the AO u/s 69A of the Act, treating the same as unexplained money. It is an undisputed fact that the assessee did not file its ITA Nos.259, 380 & 414/SRT/2024/AY 2017-18 Reva Enterprises return of income for AY 2017–18. Despite ... assessee regarding the source of these deposits and credits, the AO rightly invoked section 69A of the Act treating the same as unexplained money. 10.1 Before the CIT(A) and the Tribunal, the ld. AR contended that the assessee firm, M/s Reva Enterprise, was dissolved on 31.03.2015 and the business