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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

Suryadevara Radhakrishna, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

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

ITA 583/HYD/2025[2020-21]Status: DisposedITAT Hyderabad31 Oct 2025AY 2020-21

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 132Section 132(4)Section 68Section 69

assessee and made addition of Rs.9 crores towards on-money paid for purchase of the property under 69 of the Act, as unexplained money and brought to tax under Section 115BBE of the Income Tax Act, 1961. 6. Being aggrieved by the assessment order, the assessee preferred an appeal before ... relevant evidences, has rightly made addition of Rs. 9 crores towards on-money for purchase of property under Section 69 of the Act as unexplained money. The Ld. CIT(A), after considering relevant facts, has rightly sustained the addition made by the A.O. Therefore, she submitted that the addition made

Sree Satya Prakash Nalamati, Hyderabad vs. Income Tax Officer, Ward - 6(1), Hyderabad

ITA 1431/HYD/2025[2017-18]Status: DisposedITAT Hyderabad31 Oct 2025AY 2017-18

Bench: Us:

Section 142(1)Section 144Section 282Section 69A

Without prejudice to the above, the ld. CIT(A) erred in sustaining the addition made by the AO of Rs.18,03,730 as unexplained money u/s.69A of the Act. 3. The authorities below failed to the basic fact that the fertile wet agricultural lands would fetch minimum agricultural income ... entire amount of cash deposit of Rs. 3 Sree Satya Prakash Nalamati vs. ITO 18,03,730/- as having been sourced out of the unexplained money of the assessee under section 69A of the Act. 3. Aggrieved, the assessee carried the matter in appeal before the CIT(A). 4. Ostensibly

Prathiba Educational Society, Hyderabad vs. Income Tax Officer, Ward-6(4), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1424/HYD/2025[2017-18]Status: DisposedITAT Hyderabad31 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.1424/Hyd./2025 िनधा"रण वष"/Assessment Years 2017-2018 Prathiba Educational The Income Tax Officer, Society, Hyderabad. Ward-6(4), Pin – 500 038 Vs. Hyderabad. Pan Aaatp4036B. Pin – 500 001 (Appellant) (Respondent) िनधा""रती "ारा/Assessee By : Ca Sanket Milind Joshi राज" व "ारा/Revenue By : Sri Krishna Moorthy K. Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28.10.2025 घोषणा की तारीख/Pronouncement: 31.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: CA Sanket Milind JoshiFor Respondent: Sri Krishna Moorthy K. Sr. AR
Section 115Section 142(1)Section 143(2)Section 69Section 69A

hand as per regularly maintained books of account. 3. The learned AO has erred in treating the cash deposits into bank accounts as unexplained money u/s 69A ignoring the fact that, cash balance deposited into the bank accounts was recorded in the cash book maintained in the regular course ... accounts and section 69A applies only to unexplained money not recorded in the books of accounts and/or offers no explanation. 4. That the learned AO having been admitted the cash on hand balance by verifying the cash withdrawals from bank accounts, ought not to have considered such admitted cash

Narsinga Rao Aleti, Nalgonda vs. ITO., Ward-1, Suryapet

ITA 1419/HYD/2025[2015-16]Status: DisposedITAT Hyderabad31 Oct 2025AY 2015-16

Bench: Us:

Section 147Section 148Section 148ASection 149Section 249(4)(b)Section 271(1)(c)Section 69A

bank account No.327502010012002 with Union Bank of India, Ghatkesar Branch, Ranga Reddy District as having been sourced out of the asessee’s unexplained money under section 69A of the Act. Also, the AO while culminating the assessment initiated the penalty proceedings under section

Madhusudhan Reddy Lakkireddy, Siddipet vs. Income Tax Officer, Ward-1, Siddipet

ITA 1416/HYD/2025[2017-18]Status: DisposedITAT Hyderabad31 Oct 2025AY 2017-18

Bench: Us:

Section 142(1)Section 144Section 282Section 694Section 69A

Without prejudice to the above, the Id. CIT(A) erred in sustaining the addition made by the AO of Rs. 16,86,550 as unexplained money u/s.694 of the Act. 3. The ld. CIT(A) erred in confirming the addition of Rs.20,682, which is interest income from bank ... Rs.3 lakhs. Accordingly, the AO held the entire amount of cash deposits of Rs.16.20 lakhs as having been sourced out of the assessee’s unexplained money under section 69A of the Act. Apart from that, an independent unexplained credit of Rs.66,550/- on 20/12/2016 in the assessee’s bank account

Varshita Jain, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

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

ITA 1169/HYD/2025[2017-18]Status: DisposedITAT Hyderabad31 Oct 2025AY 2017-18

Bench: Us:

Section 144Section 69A

entire amount 3 Varshita Jain vs DCIT of cash deposits of Rs. 14,72,548/- as having been sourced out of the assessee’s unexplained money under Section 69A of the Act. Accordingly, the AO completed the assessment vide an ex parte order under Section 144 of the Act, assessing

DCIT, Central Circle-1(3), Bengaluru vs. Mangaldeep Chains, Bengaluru

ITA 2562/BANG/2024[2020-21]Status: DisposedITAT Bangalore31 Oct 2025AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Shri T. Srinivasa, CA
Section 115BSection 133ASection 139(1)Section 143(2)Section 28Section 69ASection 69B

addition u/s. 28 to 44DA. However this should have been shown under Schedule in the Income Tax return ld.sl.4 of other sources as unexplained money etc. u/s. 69A of the Income Tax Act and assessing officer completed the assessment and income was stated as unexplained money ... item or items of addition under section 28 to 44AD". However, this should have been shown under Schedule ld s1.4 of "other sources" as unexplained money etc under section 69A of the income tax act. Hence it is proposed to complete the assessment accordingly". Unquote Page

DCIT, Central Circle-1(3), Bengaluru vs. Mangaldeep Chains, Bengaluru

ITA 2561/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Oct 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Shri T. Srinivasa, CA
Section 115BSection 133ASection 139(1)Section 143(2)Section 28Section 69ASection 69B

addition u/s. 28 to 44DA. However this should have been shown under Schedule in the Income Tax return ld.sl.4 of other sources as unexplained money etc. u/s. 69A of the Income Tax Act and assessing officer completed the assessment and income was stated as unexplained money ... item or items of addition under section 28 to 44AD". However, this should have been shown under Schedule ld s1.4 of "other sources" as unexplained money etc under section 69A of the income tax act. Hence it is proposed to complete the assessment accordingly". Unquote Page

ACIT-CC-7(3), Mumbai vs. Swikrutee Finance Private Limited, Mumbai

In the result, Appeal filed by the Revenue Department stands dismissed

ITA 610/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankarassessment Year: 2014-15 Acit-Cc-7(3) Swikrutee Finance Private Room No. 655, Floor 6Th, Limited Aayakar Bhavan, M.K.Road, Office No. Ii 289 Emca Vs. Mumbai- 400020 House, S B S Road, Mumbai 400001 Pan: Aaocs2723H (Appellant) (Respondent) Present For: Assessee By : Shri Vimal Punmiya Shri Anand Mundra Revenue By : Shri Leyaqat Ali Aafaqui, Ld. Sr.A.R. Date Of Hearing : 29.09.2025 Date Of Pronouncement : 31.10.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Revenue Against The Order Dated 24.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Exemption) (In Short ‘Ld. Commissioner’) U/S 250 Of The Income Tax Act, 1961 (In Short ‘Act’) For The Assessment Year 2014-15. 2. In The Instant Case, The Assessee Is Registered As Non-Banking Financial Company (Nbfc) With Reserve Bank Of India & Engaged In The Financial Requirement Of Emerging Small & Medium Enterprises (Sme) Segment, Including Rendering An Advisory Services Relating To Financial Aspect.

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. Sr.A.R
Section 143(3)Section 147Section 148Section 250

thus on the aforesaid facts and circumstances ultimately treated the amount of Rs. 1,95,00,000/- as accommodation entry and unexplained money u/s 68 of the Act and added the same in the income of the assessee taxable u/s 115JB of the Act. 7. The assessee being aggrieved challenged

Assistant Commissioner of Income Tax-17(1) Mumbai, Mumbai vs. Fairdeal Electronics, Mumbai

In the result, appeal filed by the Revenue and CO filed by the Assessee, stands dismissed

ITA 4088/MUM/2025[2017]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankarassessment Year: 2017 & Co No. 211/M/2025 Assessment Year: 2017-18

For Appellant: Shri Nishit Gandhi a/w Adnya BhandariFor Respondent: Ms. Kavita P. Kaushik, Ld. Sr.D.R
Section 250Section 263

circulation of SBN was proscribed during the period of demonetization and therefore SBN deposited in excess of cash balance as on 08.11.2016 is unexplained money and assessable as such. In the present case, the cash balance as on 08.11.2016 was Rs. 1,03,68,905/- as per the cash book ... furnished by the Appellant. Therefore, Rs. 6,93,095/- is unexplained money. The addition made buy the AO is confirmed to this extent”. 7. Both the parties being aggrieved have preferred their respective appeal and CO, which are under consideration before us. 4 & CO No. 211/M/2025 Fairdeal Electronics

Indo Plastic Co, Delhi vs. ACIT, Circle- 49(1), Delhi

In the result the appeal of the assessee is allowed

ITA 5481/DEL/2025[2020-21]Status: DisposedITAT Delhi31 Oct 2025AY 2020-21

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2020-21

For Appellant: Shri Rajeev Mago, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 132Section 148Section 69A

failed to furnish. In view of the above, the AO passed an order by making addition of Rs. 31,35,185/- on account of unexplained money u/s 69A of the Act and the same is added back to the total income of the assessee. Against the same, assessee preferred

Tankeshwar Gohil, Gautam Buddha Nagar vs. ITO Ward-5(3)(5), Gautam Budh Nagar

Appeal is partly allowed

ITA 276/DEL/2025[2017-18]Status: DisposedITAT Delhi31 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18

Section 115BSection 143(3)Section 69A

sole substantive ground herein challenging both the learned lower authorities’ action treating his cash deposits during demonetization amounting to Rs. 150,06,200/- as unexplained money u/s 69A read with section 115BBE of the Act; in assessment order dated 23.03.2023 as upheld in the lower appellate discussion. 3. Both

Income Tax Officer, City Centre, Gwalior vs. Ajay Singh, Gwalior

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

ITA 405/AGR/2025[2018-19]Status: DisposedITAT Agra30 Oct 2025AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Sunil Kumar Singh

For Appellant: NoneFor Respondent: Shri Ajay Kumar Yadav, CIT DR
Section 133(6)Section 142Section 148Section 69A

said bank account are proposed to be added in total income of assessee u/s 69A r. w.s 115BBE of the Act as unexplained Money. Accordingly, Assessing Officer made the addition of Rs.8,84,00,000/-. 4. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi ... both in law and on facts, in treating the total cash deposits of Rs.8,81,00,000/- in the assessee's bank accounts as unexplained money under section 69A of the Income Tax Act, 1961, without appreciating that the assessee was merely an employee of M/s ISS SDB Security Services

Shri Praveen Shivhare, Gwalior vs. National Faceless Assessment Centre, Delhi, Gwalior

In the result, appeal is allowed for statistical purposes

ITA 561/AGR/2024[2015-16]Status: DisposedITAT Agra30 Oct 2025AY 2015-16

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2015-16

Section 143(2)Section 147Section 148Section 250Section 69A

appellant's income on the allegation of unexplained cash deposits in the bank account of the appellant by treating the same as unexplained money under the provisions of s.69A of the Act, without properly considering and appreciating the submissions made by the appellant along with ample of documentary evidences

Umrav Singh, Jaipur vs. ITO Ward 1, Sri Ganganagar

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

ITA 783/JODH/2024[2018-19]Status: DisposedITAT Jodhpur30 Oct 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Ms. Radhika Gupta, CA (Adjournment Application)For Respondent: Shri Arvind Kumar Gehlot, Addl. CIT-DR
Section 144Section 147Section 234ASection 249(3)Section 69A

NFAC, Delhi, erred in sustaining addition of Rs. 12,50,000/- made to the total income of the Appellant on account of unexplained money, deposited into the bank, under the provisions of section 69A of the Income Tax Act, 1961. 3. That, the Ld. CIT(A), NFAC, Delhi, erred ... short-term capital gains arising from sale of property and further made an addition of Rs.12,52,000/- treating the same as unexplained money under section 69A of the Act. The total assessed income was determined at Rs.72,52,000/-, and consequential demand was raised against the assessee 5. Aggrieved

Umrav Singh, Jaipur vs. ITO Ward 1, Sri Ganganagar

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

ITA 782/JODH/2024[2018-19]Status: DisposedITAT Jodhpur30 Oct 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Ms. Radhika Gupta, CA (Adjournment Application)For Respondent: Shri Arvind Kumar Gehlot, Addl. CIT-DR
Section 144Section 147Section 234ASection 249(3)Section 69A

NFAC, Delhi, erred in sustaining addition of Rs. 12,50,000/- made to the total income of the Appellant on account of unexplained money, deposited into the bank, under the provisions of section 69A of the Income Tax Act, 1961. 3. That, the Ld. CIT(A), NFAC, Delhi, erred ... short-term capital gains arising from sale of property and further made an addition of Rs.12,52,000/- treating the same as unexplained money under section 69A of the Act. The total assessed income was determined at Rs.72,52,000/-, and consequential demand was raised against the assessee 5. Aggrieved

Umrav Singh, Jaipur vs. ITO Ward 1, Sri Ganganagar

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

ITA 781/JODH/2024[2018-19]Status: DisposedITAT Jodhpur30 Oct 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Ms. Radhika Gupta, CA (Adjournment Application)For Respondent: Shri Arvind Kumar Gehlot, Addl. CIT-DR
Section 144Section 147Section 234ASection 249(3)Section 69A

NFAC, Delhi, erred in sustaining addition of Rs. 12,50,000/- made to the total income of the Appellant on account of unexplained money, deposited into the bank, under the provisions of section 69A of the Income Tax Act, 1961. 3. That, the Ld. CIT(A), NFAC, Delhi, erred ... short-term capital gains arising from sale of property and further made an addition of Rs.12,52,000/- treating the same as unexplained money under section 69A of the Act. The total assessed income was determined at Rs.72,52,000/-, and consequential demand was raised against the assessee 5. Aggrieved

Vikram Singh, Balotra vs. Income Tax Officer, Balotra

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

ITA 522/JODH/2024[2017-18]Status: DisposedITAT Jodhpur30 Oct 2025AY 2017-18
Section 69A

deposits were related to trade, they were not legally permissible. The Department contended that such deposits clearly fell within the ambit of unexplained money under section 69A and the orders of the Assessing Officer and the CIT(A) deserved to be upheld. 7. We have carefully considered the rival submissions ... Bench of the ITAT Jodhpur, where in identical facts it was held that trade receipts duly recorded in the books cannot be taxed as unexplained money merely because they were received in SBNs during demonetisation. 8. In the result, the appeal of the assessee is partly allowed. The addition

Kapil Marlecha, Pali vs. ITO, Ward-3, Pali

In the result, appeal of the Assessee is partly allowed

ITA 248/JODH/2024[2017-18]Status: DisposedITAT Jodhpur30 Oct 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Rajendra Jain, AdvocateFor Respondent: Shri Arvind Kumar Gehlot, Addl. CIT DR
Section 115BSection 142(1)Section 144Section 69A

assessee failed to furnish explanations or supporting documents. 4.2 Consequently, the AO completed the assessment u/s 144, treating the entire deposits as unexplained money u/s 69A and taxed under section 115BBE. 5. Against the order of the AO the assessee carried the matter before the CIT(A), NFAC. During ... burden cast under section 69A. In absence of verifiable evidence, the entire cash deposit of Rs.17,38,500/-  has rightly been treated as unexplained money. 8.1 The DR therefore urged that the order of the CIT(A), confirming the full addition, be sustained. 9. We have considered rival submissions

Gen Singh, Jodhpur vs. ITO, Ward-3(5), Jodhpur

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

ITA 408/JODH/2023[2017-189]Status: DisposedITAT Jodhpur30 Oct 2025AY 2017-189

Bench: SHRI. LALIET KUMAR (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Amit Kothari, C.AFor Respondent: Shri Arvind Kumar Gehlot, Addl. CIT DR
Section 115BSection 142(1)Section 144Section 250Section 69A

Statutory notices u/s 142(1) were issued but remained uncomplied with. The AO therefore completed assessment ex parte u/s 144 treating the deposits as unexplained money u/s 69A and determined total income at Rs. 25,68,455 taxable u/s 115BBE. 3. Against the order of the AO the assessee filed