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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

DCIT, Circle1(1), Kolkata vs. Arthur Turnkey Projects Ltd, Kolkata

In the result, ITA No.1724/Kol/2025 filed by the revenue is dismissed and the appeal of the assessee being ITA No

ITA 1724/KOL/2025[2017-18]Status: DisposedITAT Kolkata12 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Dcit, Circle-1(1), Kolkata.……………………………………….……….……Appellant Vs. Arthur Turnkey Projects Ltd.……………………………….....……...…..…..Respondent 1/1A, 4H Electronic Centre, Biplabi Anukul Chandra Street, Chandni Chawk, Kol-700072. [Pan: Aafcm4891H] Assessment Year: 2017-18 Arthur Turnkey Projects Ltd.……………………………………….……….……Assessee 1/1A, 4H Electronic Centre, Biplabi Anukul Chandra Street, Chandni Chawk, Kol-700072. [Pan: Aafcm4891H] Vs. Dcit, Circle-1(1), Kolkata.…………………………………….....……...…………..Revenue Appearances By: Shri Robin Maheshwari, Aca, Appeared On Behalf Of The Assessee. Shri Manas Mondal, Addl. Cit-Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : November 12, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals & The Cross-Appeal, One Filed By The Revenue & The Other By The Assessee Are Directed Against The Order Both Dated 24.04.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To

Section 115JSection 143(2)Section 250Section 68

complete year cash book, names, addresses and telephone numbers of person to whom cash sales were made, such sales could not be considered as unexplained money and that too when profit derived from those sales proceeds was already taxed as part of sales”. Further, in the case of ACIT

M/S. Arthur Turnkey Projects Ltd., Kolkata vs. DCIT/ACIT, Circle - 1(1), Kolkata

In the result, ITA No.1724/Kol/2025 filed by the revenue is dismissed and the appeal of the assessee being ITA No

ITA 1193/KOL/2025[2017-2018]Status: DisposedITAT Kolkata12 Nov 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Dcit, Circle-1(1), Kolkata.……………………………………….……….……Appellant Vs. Arthur Turnkey Projects Ltd.……………………………….....……...…..…..Respondent 1/1A, 4H Electronic Centre, Biplabi Anukul Chandra Street, Chandni Chawk, Kol-700072. [Pan: Aafcm4891H] Assessment Year: 2017-18 Arthur Turnkey Projects Ltd.……………………………………….……….……Assessee 1/1A, 4H Electronic Centre, Biplabi Anukul Chandra Street, Chandni Chawk, Kol-700072. [Pan: Aafcm4891H] Vs. Dcit, Circle-1(1), Kolkata.…………………………………….....……...…………..Revenue Appearances By: Shri Robin Maheshwari, Aca, Appeared On Behalf Of The Assessee. Shri Manas Mondal, Addl. Cit-Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : November 12, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals & The Cross-Appeal, One Filed By The Revenue & The Other By The Assessee Are Directed Against The Order Both Dated 24.04.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To

Section 115JSection 143(2)Section 250Section 68

complete year cash book, names, addresses and telephone numbers of person to whom cash sales were made, such sales could not be considered as unexplained money and that too when profit derived from those sales proceeds was already taxed as part of sales”. Further, in the case of ACIT

Income Tax Officer, Ludhiana vs. Deep Trading Co., Ludhiana

The appeal of the Revenue is dismissed

ITA 477/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 477/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Income Tax Officer, Deep Trading Co., Room No. 228, First Floor, बनाम B 34-5503, Aaykar Bhawan, Rishi Nagar, 22 Footi Road, Vs. Ludhiana Haibowal Kalan, Ludhiana "थायी लेखा सं./ Pan No: Aahfd6122B अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : None राज"व क" ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 03.09.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.11.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 20.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Pertaining To A.Y. 2012-13. 2. Grounds Of Appeal Are As Under:

For Appellant: NoneFor Respondent: Sh. Manav Bansal, CIT DR
Section 144Section 251(1)Section 251(1)(a)

Income Tax (Appeals) has failed to appreciate the fact that the addition of Rs. 11,12,71,500/- made by the AO as unexplained money on account of unexplained cash Deposits in bank accounts as the assessee not furnished 477-Chd-2025 Deep Trading Co., Ludhiana reply evidence regarding