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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

M/S. Ambattur Developers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-1(1), Chennai

ITA 2601/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2601/Chny/2024 निर्धारण वर्ष / Assessment Year: 2015-16 M/S. Ambattur Developers Private Limited, (Amalgamated With Ambattur Hotels Private Limited) No. 86/E2, Industrial Estate, Ambattur, Chennai - 600 058. Tamil Nadu. [Pan: Aaeca-7490-D] (अपीलार्थी/Appellant) Income Tax Officer, Vs. Corporate Ward- 1(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. R. Vijayaraghavan, Advocate : Shri. Bipin, C.N., Cit सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 11.11.2025 आदेश /Order Per S.R.Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A)) For The Assessment Year 2015-16, Vide Order Dated 12.08.2024. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Respondent: Shri. R. Vijayaraghavan, Advocate
Section 50CSection 56(2)(vii)

proof on closely held companies for funds received from shareholders, and taxation of share premium in excess of fair market value. • Taxation of unexplained money, credits, investments, or expenditures at 30%, irrespective of income slab.” (emphasis supplied) 9.2 From the above memo it is evident that introduction of section ... unaccounted monies. It is evident that the provision was not meant to disturb genuine, bona fide business transactions but to curb tax abuse through unexplained money inflows. In the instant case, neither the AO nor the Id.CIT(A) have held or alleged that unaccounted money has been introduced

Leo Bhaginath, Malaparamba, Kozhikode vs. ITO, Ward-1(2), Kozhikode

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

ITA 626/COCH/2025[2016-17]Status: DisposedITAT Cochin10 Nov 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am Assessment Years: 2016-17 Leo Bhagianath .......... Appellant 34/290, Malaparamba, Kozhikode 673009 [Pan: Adtpl7403Q] Vs. The Income Tax Officer, Ward-1(2), Kozhikode .......... Respondent Assessee By: Shri Anand Kumar, V.K, Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 10.11.2025 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 09.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Deriving Income As An Advocate. The Return Of Income For Ay 2017- 18 Was Filed On 21.10.2017 Declaring Income Of Rs. 5,50,000/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward 1(2), Kozhikode (Hereinafter Called "The Ao") Vide Order Dated 04.12.2019 Passed U/S. 143(3) Of The Income Tax Act, 1961 (The Act) At A Total Income Of Rs. 42,72,800/-. While Doing So, The Ao Brought To Tax The Credits In The Bank

For Appellant: Shri Anand Kumar, V.K, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 44A

While doing so, the AO brought to tax the credits in the bank 2 Leo Bhagianath account of Rs. 36,04,500/- as unexplained money of the appellant. He also brought to tax the interest on bank deposit of Rs. 1,18,300/-. 3. Being aggrieved, an appeal was filed ... Therefore, the CIT(A), held that only the balance amount of Rs. 25,65,500/- should be brought to tax as unexplained money of the appellant. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The appellant had filed an application seeking admission