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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

Thanushkodi Narayanan, Chennai vs. DCIT, Central Circle-3(2), Chennai

ITA 2570/CHNY/2025[2011-12]Status: DisposedITAT Chennai09 Mar 2026AY 2011-12

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

Section 132Section 142Section 142(1)Section 143(2)Section 153A

Foreign Travel Expenses Unexplained investment u/s 69 Unexplained money 2,81,25,000 (16.1-16.5) 3,00,000 (12.1 - 12.5) 158-169 63. We find that the additions made in the search assessment order for the Assessment Year 2012-13 to 2016-17 are extract replicate of the annexures forming

Vinod Kumar Kailashchandra Verma, Raipur vs. Income Tax Officer, Ward-1(3), Raipur

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

ITA 69/RPR/2026[2015-16]Status: DisposedITAT Raipur06 Mar 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 69/Rpr/2026 (िनधा"रण वष" Assessment Year: 2015-16) Vinod Kumar Khailashchandra Verma, Vs Income Tax Officer, Ward 3(1), House No.496/9, Avanti Vihar, Sector-2, Central Revenue Building, Telibandha, Raipur-492001 (C.G.) Civil Lines, Raipur, C.G. 492001 Pan: Aanpv5964B (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. (Adjournment Petition Filed.) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख / Date Of : 06/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

For Appellant: None. (Adjournment petition filed.)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 144Section 147Section 148Section 151Section 249(2)Section 249(3)Section 250Section 69A

wherein following additions, in absence of any compliance on the part of the assessee, were made: SI. Description Amount (in INR) 1. Unexplained money u/s 69A Rs.1,00,36,750/- 2. Income from Other Sources Rs.2,89,486/- 3. STCG on sale of Land Rs.59,28,000/- 4 Total income/Loss

Meridian Marketers, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 1879/HYD/2025[2022-23]Status: HeardITAT Hyderabad06 Mar 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1879/Hyd/2025 Assessment Year 2022-2023 Meridian Marketers, The Acit, Hyderabad. Telangana. Central Circle-2(1), Vs. Pin 500 033. Hyderabad. Pan Abmfm1321M Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By -None- राज" व "ारा/Revenue By : Sri Mathivanan S A, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Sri Mathivanan S A, Sr. AR
Section 131Section 132ASection 139(4)Section 139(5)Section 148Section 148ASection 250Section 69A

Appeals)- 12, Hyderabad erred in sustaining the addition of Rs.35,00,000 made by the Assessing Officer treating the cash found during search as unexplained money u/s 69A. Ground No.3 The learned Commissioner of Income Tax (Appeals) 12, Hyderabad erred in not considering the fact that the amount of Rs.35 ... place of business of the assessee. 8. The assessment was finally completed on 10th March, 2025 treating the amount of Rs.35,00,000 as unexplained money u/s 69A. The following reasons were mentioned by the Assessing Officer for such addition.  On verification of cash book submitted by Mr.Muralidhar Reddy, employee