“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

Sai Sumanth Mitta, Warangal vs. Income Tax Officer, Ward-2, Warangal

In the result, the appeal filed by the assessee is allowed

ITA 815/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-18

Bench: the Ld. CIT(A).

Section 115BSection 69A

that out of Rs. 16,60,000/-, a sum of Rs. 8,00,000/- has been declared under the PMGKY Scheme as part of unexplained money / cash deposits during the demonetization period. The remaining amount of cash deposit was only Rs. 8,60,000/-, which needs to be explained ... assessee before the date of demonetization, in our considered view, the reasons given by the A.O. to make additions towards cash deposits as unexplained money under Section 69 of the Act is contrary to the evidence available on record and thus, cannot be sustained. The Ld. CIT(A), without appreciating

Meraj Anjum, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

In the result, the appeal filed by the assessee is allowed

ITA 1467/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-2018

Bench: the Ld. CIT(A).

Section 69A

accepted. Therefore, rejected the explanation of the assessee and made additions of Rs. 19,74,500/- under Section 69A of the Act, as unexplained money towards cash deposits into bank account during the demonetization period. 4. Aggrieved by the assessment order, the assessee preferred appeal before

Jagadishwar Barma, Hyderabad vs. ITO, Ward-11(2), Hyderabad

ITA 1436/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-18

Bench: Us:

Section 115BSection 143(3)Section 2(14)Section 294Section 69A

Learned CIT(A) erred in upholding the action of the Assessing Officer in treating cash deposits of Rs. 30,79,000/- as unexplained money u/s 69A of the Act, despite sufficient and proper evidence being furnished regarding the source of such deposits. 3. The Learned CIT(A) failed to appreciate ... explanation and held the entire amount of cash deposits of Rs. 30,79,000/- as having been sourced out of the assessee’s unexplained money under Section 69A of the Act. 4. Aggrieved, the assessee carried the matter in appeal before the CIT(Appeals), wherein he assailed the order

Hamasamani Silks, Kancheepuram vs. ITO, Ward-1, Kancheepuram

In the result, the appeal stands partly allowed

ITA 2664/CHNY/2025[2017-18]Status: DisposedITAT Chennai07 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:2664/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 & S.A. No.100/Chny/2025 [In I.T.A. No.2664/Chny/2025] िनधा$रण वष$ / Assessment Year: 2017-18

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T

Section 147Section 44ASection 68

ITA.No.698/Chny/2022 dated 07.02.2023 and stressed on the point that deposit of SBN during demonetization period has to be taxed as unexplained money and therefore, the Ld.Sr.DR requested to confirm the order of the lower authorities. 5. Having heard the rival submissions and upon perusal of case records, our adjudication ... added. Merely because there is an incremental difference :-5-: S.A.No.100/Chny/2025 & ITA. No.:2664 /Chny/2025 cannot lead to a presumption that there is an unexplained money. In fact, and as observed by the AO, in the very next AY there is a decrease in the sales turnover and consequently

Vyavasaya Seva Sahakara Bank Niyamitha Antharagatte, Chickmagalur vs. Income Tax Officer, Ward-1, Chickmagalur, Chikamangalur

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

ITA 124/BANG/2025[2018-19]Status: DisposedITAT Bangalore07 Nov 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2018-19

For Respondent: Shri Narendra Sharma &

Section 144Section 148Section 148ASection 69A

with the AO, the best judgement assessment u/s. 144 was made in which the cash deposits made to the bank account was treated as unexplained money u/s. 69A of the Act. As against the said order, the assessee filed an appeal before the Ld.CIT(A) with a delay

Yusuf Ashraf Shaikh, Mumbai vs. Income Tax Officer - Ward 27(3)(1), Mumbai

In the result, the appeal stands allowed for statistical

ITA 2898/MUM/2025[2018-19]Status: DisposedITAT Mumbai07 Nov 2025AY 2018-19

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Shri Chirayu Panarkar,ARFor Respondent: Shri Swapnil Choudhary, (Sr.AR)

Section 143(2)Section 143(3)Section 253Section 68Section 69A

assessed him by making addition of Rs.15,28,88,700/- to its income invoking provisions of section 69A of the Act, treating it as Unexplained Money. 6. Aggrieved, the assessee filed appeal before the ld.CIT(A) contesting the addition and filed certain additional evidences which were admitted by him. With

Prashant Kumar, Delhi vs. Asst CIT, Circle 70(1), Delhi

Appeal is allowed in the aforesaid terms

ITA 5624/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18

For Appellant: Sh. M.K. Bhatt, CA & Sh. Malav Gosowami, AdvFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142(1)Section 143(2)Section 15BSection 69A

treated the same as disclosed income and completed the assessment proceedings making addition of undisclosed income of Rs. 15,00,000/- on account of unexplained money u/s. 69A of the Act and added the same to the total income of the assessee and taxed u/s. 15BBE of the Act. Aggrieved

Niraj Kumar Singh, Delhi vs. Income Tax Officer 70(5), Delhi

Appeal is partly allowed in the aforesaid terms

ITA 5556/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18

For Appellant: NoneFor Respondent: Shri Manoj Kumar, Sr. DR

Section 115Section 115BSection 143(3)Section 69A

give valid explanation about the nature and source of cash deposits, hence the value of cash deposits during demonetization period is deemed as unexplained money u/s. 69A of the Income Tax Act, 1961 read with section 115BBE of the Act and added to the total income of the assessee

Shri Likha Saaya, Nirjili vs. Income Tax Officer, Ward- North Lakhimpur., Lakhimpur

In the result, both the appeals of the assessee are allowed

ITA 50/GTY/2021[2011-12]Status: DisposedITAT Guwahati06 Nov 2025AY 2011-12

Bench: S/Shriand Rajesh Kumarand Manmohan Dasita Nos.49 & 50/Gty/2021 Assessment Years : 2010-11 & 2011-12 Shri Likha Saaya S/O. Shri Likha Vs. Ito, Ward-North, Lakhimpur Heli, P-Sector, P.O. Nirjuli, Borah Complex, D.K.Road, North District Papumpare, Arunachal Lakhimpur, Lakhimpur, Assam- Pradesh-791109 787001 Pan/Gir No. (Appellant) .. ( Respondent) Assessee By : Sarala Agarwal. Ar Revenue By : Shri Kausik Ray, Jcit

For Appellant: Sarala Agarwal. ARFor Respondent: Shri Kausik Ray, JCIT

Section 10(26)Section 143(1)Section 143(2)Section 144

withdrawals of cash from the bank account of the assessee, then same cannot be added to the income of the assessee as unexplained money. Ld. AR submitted that this is simple withdrawals and deposits of cash either in the same bank account or to another account, which did not generate

Shri Likha Saaya, Nirjili vs. Income Tax Officer, Ward- North Lakhimpur., Lakhimpur

In the result, both the appeals of the assessee are allowed

ITA 49/GTY/2021[2010-11]Status: DisposedITAT Guwahati06 Nov 2025AY 2010-11

For Appellant: Sarala Agarwal. ARFor Respondent: Shri Kausik Ray, JCIT

Section 10(26)Section 143(1)Section 143(2)Section 144

Laljibhai Dudabhai Bhuva, Rajkot vs. Income Tax Officer, Ward-2(2)(1), Rajkot.

In the result, appeal filed by the assessee is allowed partly in above terms

ITA 501/RJT/2025[2017-18]Status: DisposedITAT Rajkot06 Nov 2025AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./ Ita No.501/Rjt/2025 िनधा"रण वष"/Assessment Year : 2017-18

For Appellant: Shri Digant Kyada, Ld. ARFor Respondent: Shri Dheeraj Kumr Gupta, Ld. Sr. DR

Section 142(1)Section 144Section 250Section 69A

made by him in his Bank account no.614049000881 held in Ramod Branch during Demonetisation period between 09/11/2016 to 30/12/2016 be treated as unexplained money u/s.69A of the Act and added to his total income for A.Y.2017-18. The assessee was asked to submit his reply by 27/06/2019 but once again

Assistant Commissioner of Income Tax, Central Circle-2, Ernakulam, Kochi vs. Samaira Properties Pvt.Ltd., Thiruvananthapuram

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

ITA 609/COCH/2025[2020-21]Status: DisposedITAT Cochin06 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2020-21 Acit, Central Circle - 2, Ernakulam .......... Appellant Vs. Samaira Properties Pvt. Ltd .......... Respondent Samaira House, Kra-D6, Kowdiar Thiruvananthapuram 695003 [Pan: Abbcs6500L] Assessee By: Shri Anoop V.Francis, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 03.11.2025 Date Of Pronouncement: 06.11.2025

For Appellant: Shri Anoop V.Francis, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 139(1)Section 144

discharge the onus of proving that the said amounts were for land development works, the AO had brought to tax the same as unexplained money of the appellant vide assessment order dated 25.08.2022 passed u/s. 144 r.w.s. 153A of the Act. 3. Being aggrieved, an appeal was filed before

Nishad Moothedam Muhammadali, Vazhakulam vs. The Income Tax Officer, Aluva

In the result, the appeal filed by the assessee stands partly

ITA 469/COCH/2025[2019-20]Status: DisposedITAT Cochin06 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm

For Appellant: Revenue byFor Respondent: Date of Hearing

Section 147Section 148Section 148A

bank accounts of ICICI Band and South Indian Bank and cash withdrawals from the said banks aggregating to Rs. 5,09,03,315/- as unexplained money of the appellant. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order dismissed the appeal

Harwinder Singh, Sangrur vs. ITO Ward Sangrur, Sangrur

Appeal of the assessee is treated as allowed for statistical purposes

ITA 414/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh06 Nov 2025AY 2012-13

Bench: SH. SANJAY GARG (Judicial Member)

For Appellant: Shri Rakesh Cajla, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT,Sr.DR

Section 147Section 148Section 69A

Addl./JCIT (A)-4, Mumbai is not justified in upholding the addition aggregating to Rs. 1483000/- in treating the entire cash deposits as unexplained money u/s 69A of the Income Tax Act. 7. That the assessee craves, leave, to add, amend or delete any of the grounds of appeal before

Income-Tax Officer, Ward-4(2)(1), Ahmedabad vs. Late Khodaji Ranchhodji Thakor Legal Heir Narendakumar Khodaji Thakor, Ahmedabad

In the result, the appeal filed by the Revenue is, therefore, dismissed

ITA 948/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.948/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 The Ito Late Khodaji Ranchhodji Ward-4(2)(1) बनाम/ Thakor V/S. Ahmedabad – 380 015 Legal Heir Narendrakumar Khodaji Thakor Ahmedabad – 382 481 "थायी लेखा सं./Pan: Afwpt 1453 K (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 24/02/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri B.P. Srivastava, Sr.DR

Section 133(6)Section 142(1)Section 144Section 148Section 250

notice und consequent assessment and deleting various additions totalling to Rs. 1,73,64,690/- (Rs. 1,41,94,690/- on account of unexplained money and Rs. 31,70,000/-on account of unexplained investment) on the ground that the assessee had expired before issue of Notice ... addition ITO vs. Late Khodaji Ranchhodji Thakor Legal Heir Narendrakumar Khodaji Thakor Asst. Year : 2017-18 4 of Rs. 1,41,84,687/- as unexplained money under section 69A of the Act and taxed the same under section 115BBE at the rate of 60%. Further, the AO made an addition

Malini Jignesh Doshi, Ahmedabad vs. ITO Ward 5(3)(1), Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 755/AHD/2025[2017-2018]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2017-2018

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Ankit Choksi, ARFor Respondent: Shri Ravindra, Sr. DR

Section 115BSection 143(3)Section 271ASection 69A

Assessing Officer completed the assessment under section 143(3) of the Act and treated the cash deposits aggregating to Rs. 17,63,000/- as unexplained money under section 69A of the Act and applied the tax at the rate specified in section 115BBE of the Act. Accordingly, the assessee computed

Mohanbhai Becharbhai Chauhan, Ahmedabad vs. Income Tax Officer Ward 1(2)(3), Ahmedabad

ITA 1570/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Vidhi V. Pandya, CAFor Respondent: Shri Ravindra, Sr. DR

Section 144Section 147Section 234ASection 234BSection 271FSection 272ASection 272A(1)(b)Section 272A(1)(c)Section 69Section 69A

assessee with regards to the source of the cash deposits and the fixed deposit, treated the aggregate sum of Rs. 9,00,000/- as unexplained money under section 69A of the Act and added the same to the total income of the assessee. 4. In appeal before CIT(Appeals ... Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) and McDowell & Co. Ltd. v. CTO [1985] 154 ITR 148 (SC), and held that unexplained money, if not properly explained by the assessee, can be assessed as income under section 69A of the Act. Accordingly, the addition

Nagaraj Sujatha, Bangalore vs. Income Tax Officer, Ward-4(2)(1), Bangalore

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

ITA 1649/BANG/2024[2012-13]Status: DisposedITAT Bangalore06 Nov 2025AY 2012-13

Bench: Shri Waseem Ahmedassessment Year: 2012-13

For Appellant: Shri S.V Ravishankar, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250(6)Section 69A

view that the assessee had failed to explain the source of cash deposits in the bank account. Accordingly, he treated the same as unexplained money under section 69A of the Act. The assessee, however, had pointed out that the AO himself recorded in the order that there was cash withdrawal

Jayshree Viradiya, Surat vs. ITO, Ward 3(2)(9), Surat

In the result, The appeal of the assessee is allowed for statistical purpose

ITA 323/SRT/2025[2017-18]Status: DisposedITAT Surat04 Nov 2025AY 2017-18

Bench: Shri Diesh Mohan Sinha & Shri Bijayananda Prusethआयकरअपीलसं./Ita No. 323/Srt/2025 (निर्धारणवर्ा / Assessment Year: (2017-18) (Hybrid Hearing) Jayshree Viradiya 305, 3Rd Floor, Vs. Ito Ward 3(2)(9), Anavil Sharda Apartment, Chandulal Business Centre, Adajan Sheths Street, Saiyedpura, Surat- Hazira Road, Adajan, Surat. 395003. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agipv9311R (Appellant) (Respondent) Appellant By : Shri P M Jagasheth, Ca Respondent By : Shri Ravi Kant Gupta, Cit(Dr) : 06/08/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac) Cit(A) Dated 24.01.2025, Which In Turn Arises Out Of An Assessment Order Dated 15.11.2019 Passed By Assessing Officer Under The Income Tax Act, 1961. Ita 323/Srt/2025 Jayshree Viradiya 2. Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri P M Jagasheth, CAFor Respondent: Shri Ravi Kant Gupta, CIT(DR)

Section 115BSection 144Section 271ASection 69A

making addition of Rs. 19,24,300/-on account of alleged cash deposit and other credits in a saving bank account treated as alleged unexplained money u/s.69A.rws u/s 115BBE The Income Tax Act, 1961. 2. On the facts and in the circumstances of the case as well ... reasons appellant failed to provide sources of above credit entries made in bank account due to this learned AO consider it all amount as unexplained money u/s 69A of Income ~ 2 ~ ITA 323/SRT/2025 Jayshree Viradiya Tax Act 1961. And making addition with same amount. Subject to the above discussion, Total

Patel and Sons, Na vs. Arivs.Income Tax Officer, Ward 3, Navsari, Surat

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

ITA 166/SRT/2025[2017-18]Status: DisposedITAT Surat04 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.166/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Patel & Sons बनाम/ Ito, Raja Road, Maroli Bazar, Vs. Ward – 3, Maroli, Tal: Jalalpore, Navsari – Navsari 396436 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajfp1701E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रतीकीओरसे/Appellant By Shri Rasesh Shah, Ca राज"कीओरसे /Respondent By Shri Ajay Uke (Sr. Dr) With Shri Kevin Langaliya, Ca सुनवाई की तारीख/Date Of Hearing 04/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 04/11/2025

Section 115BSection 139(1)Section 142(1)Section 250Section 69A

erred in confirming the action of AO in making the addition of Rs.12,07,000/- u/s.69A of the IT Act on account of alleged unexplained money being cash deposits in bank account. ITA No.166/SRT/2025/AY 2017-18 Patel & Sons (2) On the facts and circumstances of the case as well