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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

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 380/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

Reva Enterprise, Ankleshwar vs. Income Tax Officer, Ward 2(4), Bharuch

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

ITA 259/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

Singla Apparels Private Limited, Gandhi Nagar vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is allowed

ITA 5163/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2017-18] Singla Apparels Pvt.Ltd. Vs Ito House No.17, Street No.2, Ward Shankar Nagar, Gandhi Nagar, C.R. Building, Ito Krishan Nagar, Delhi-110051. I.P.Estate Pan-Aajcs3628L New Delhi-110002 Appellant Respondent [Assessment Year : 2017-18] Singla Apparels Pvt.Ltd. Vs Ito 7244, Mahavir Gali Ward Gandhi Nagar, Delhi-1100531. C.R. Building, Ito Pan-Aajcs3628L I.P.Estate New Delhi-110002 Appellant Respondent Appellant By Shri Salil Kapoor, Adv. & Shri Utkarsa Gupta, Adv. Respondent By Shri Manish Gupta, Sr.Dr Date Of Hearing 17.11.2025 Date Of Pronouncement 17.11.2025 Order Per Manish Agarwal, Am : The Captioned Appeals Are Filed By Assessee Against The Separate Orders Dt.11.06.2024 & 12.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi-8/10554/2019-20 & In Appeal No. Nfac/2016-17/10058210 Respectively, Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act & Penalty

Section 142(1)Section 143(2)Section 143(3)Section 156Section 250Section 271ASection 69A

both parties and perused the material available on record. In this case, AO has made an addition of INR 1,86,16,753/- as unexplained money u/s 69A of the Act being the ITA Nos.3445 & 5163/Del/2024 cash deposited in SBN during the demonetization period claimed as made out of cash

Singla Apparels Pvt Ltd, Gandhi Nagar vs. Income Tax Officer, Ward

In the result, the appeal of the assessee is allowed

ITA 3445/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2017-18] Singla Apparels Pvt.Ltd. Vs Ito House No.17, Street No.2, Ward Shankar Nagar, Gandhi Nagar, C.R. Building, Ito Krishan Nagar, Delhi-110051. I.P.Estate Pan-Aajcs3628L New Delhi-110002 Appellant Respondent [Assessment Year : 2017-18] Singla Apparels Pvt.Ltd. Vs Ito 7244, Mahavir Gali Ward Gandhi Nagar, Delhi-1100531. C.R. Building, Ito Pan-Aajcs3628L I.P.Estate New Delhi-110002 Appellant Respondent Appellant By Shri Salil Kapoor, Adv. & Shri Utkarsa Gupta, Adv. Respondent By Shri Manish Gupta, Sr.Dr Date Of Hearing 17.11.2025 Date Of Pronouncement 17.11.2025 Order Per Manish Agarwal, Am : The Captioned Appeals Are Filed By Assessee Against The Separate Orders Dt.11.06.2024 & 12.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi-8/10554/2019-20 & In Appeal No. Nfac/2016-17/10058210 Respectively, Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act & Penalty

Section 142(1)Section 143(2)Section 143(3)Section 156Section 250Section 271ASection 69A

both parties and perused the material available on record. In this case, AO has made an addition of INR 1,86,16,753/- as unexplained money u/s 69A of the Act being the ITA Nos.3445 & 5163/Del/2024 cash deposited in SBN during the demonetization period claimed as made out of cash

Kulathumkuzhiyil Muhammed Ashraf, Kottayam vs. Income Tax Officer Ward 1 Kottayam, Kottayam

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

ITA 622/COCH/2025[2018-19]Status: DisposedITAT Cochin14 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am Assessment Years: 2018-19 Kulathumkuzhiyil Muhammed Ashraf .......... Appellant Kulathumkuzhiyil, Velloor, Kottayam 686501 [Pan: Bzvpa6849J] Vs. The Income Tax Officer, Wd-2, Kottayam .......... Respondent Assessee By: Shri Prashanth Srinivas, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 14.11.2025 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 23.06.2025 For Assessment Year (Ay) 2018-19. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Act Was Filed For Ay 2018-19. Based On The Information That The Appellant Received Interest Income From United India Insurance Company Ltd. Or Rs. 29,03,429/- During The Previous Year Relevant To Assessment Year Under Consideration, 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 2 Kulathumkuzhiyil Muhammed Ashraf 31.03.2022. The Appellant Neither Complied With The Notice U/S. 148 Nor U/S. 142(1) Of The Act Issued By The Ao Calling For Certain Information. In The Circumstances, The Ao Was Constrained To Pass Best Judgement Assessment By Bringing To Tax The Interest Income Of Rs. 29,03,429/- As Unexplained Money Of The Appellant.

For Appellant: Shri Prashanth Srinivas, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 142(1)Section 148Section 250(6)

circumstances, the AO was constrained to pass best judgement assessment by bringing to tax the interest income of Rs. 29,03,429/- as unexplained money of the appellant. 3. Being aggrieved, an appeal was filed before the CIT(A), contending that the interest income was received on account of compensation