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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

Anu Gupta, Rohini, New Delhi vs. DCIT Circle 34(1), Civic Centre, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 3106/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.3106/िद"ी/2025 (िन.व. 2017-18) Anu Gupta, 62 A, Naharpur, Sector-7, Rohini, ...... अपीलाथ"/Appellant New Delhi 110085 Pan: Auupg-3868-N बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 34(1), Civic Centre, New Delhi 110002 अपीलाथ" "ारा/Appellant By : None "ितवादी"ारा/Respondent By : Ms. Sudha Gupta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 31/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 27/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 18.11.2024, For Assessment Year 2017-18. 2. The Appeal Is Time Barred By 98 Days. The Assessee Has Filed An Application Citing Reasons Causing Delay In Filing Of Appeal. After Perusal Of The Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, The Delay Has Been Caused For The Reasons Stated In Petition Which Appears To Be Bonafide. Thus, Delay Of 98 Days In Filing Of Appeal Is Condoned & Appeal Is Admitted For Decision On Merits.

For Appellant: NoneFor Respondent: Ms. Sudha Gupta, Sr. DR
Section 115BSection 69A

hand available with the assessee. Since, no supporting documents were furnished by the assessee, the AO made addition of the entire amount as unexplained money u/s.69A r.w.s. 115BBE of the Act. Aggrieved by thesaid assessment order dated 30.12.2019, the assessee filed appeal before the CIT(A). The First Appellate Authority

Partha Roy, West Bengal vs. ITO, Ward - 50(2), Kolkata

In the result, the appeal of the assessee is dismissed as per direction given above

ITA 2700/KOL/2024[2017-18]Status: DisposedITAT Kolkata24 Oct 2025AY 2017-18

Bench: Shri Pradip Kumar Choubeyshri Rakesh Mishra & Assessment Year: 2017-18 Partha Roy…………..………….…….………………….……….……….……Appellant 923/1, Ashok Nagar, Barasat, W.B-743232. [Pan: Awepr4888F] Vs. Ito, Ward-50(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Asim Dey, Ar, Appeared On Behalf Of The Appellant. Shri Prabhakar Prakash Ranjan, Addl. Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 22, 2025 Date Of Pronouncing The Order : October 24, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 139(1)Section 142(1)Section 144Section 250Section 69A

assessee failed to give any response. The Assessing Officer thereafter completed the assessment proceedings by treating a sum of Rs.1,21,79,229/- as unexplained money u/s 69A by passing an order u/s 144 of the Act. Partha Roy 3. Aggrieved by the said order, the assessee preferred an appeal ... completed the assessment proceedings u/s 144 of the Act by treating the entire credits/deposits appearing in the bank account of the assessee as unexplained money. Before the ld. CIT(A), the assessee filed written submission, however the assessee did not produce any details or 2 Partha Roy evidences

G. Senthilkumar, Thanjavur vs. Income Tax Officer, Income Tax Department

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

ITA 2130/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Oct 2025AY 2017-18

Bench: Shri S.Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./Ita No.: 2130/Chny/2025 यनिाारण वर्ा/Assessment Year: 2017-18 Shri G. Senthilkumar, The Income Tax Officer, A24, Kannan Nagar, Vs. Che-W-192(16), 5Th Cross, Chennai Thanjavur – 613 007. Pan: Axyps 4086R (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri Gokularaman, Ca प्रत्यर्थी की ओर से/Respondent By : Shri C.P. Solomon, Cit सुनवाई की तारीख/Date Of Hearing : 23.10.2025 घोर्णा की तारीख/Date Of Pronouncement : 24.10.2025

For Appellant: Shri Gokularaman, CAFor Respondent: Shri C.P. Solomon, CIT
Section 139Section 147Section 148Section 69A

justified in confirming the addition made in the sum of Rs.4,56,48,732/- on account of cash deposits made during demonetization period as unexplained money u/s.69A of the Act in the facts and circumstances of the case. 3. We have heard rival submissions and perused the material available ... assessee stating that the credits in the bank account stood improperly explained and accordingly, proceeded to add Rs.4,56,48,732/- as unexplained money u/s.69A of the Act for want of evidence from the side of assessee. 4. Before the Ld.CIT(A), the assessee filed additional evidences under Rule

Subramanian, Coimbatore vs. ITO, Ward 1(4), Erode

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

ITA 1823/CHNY/2025[2013-14]Status: DisposedITAT Chennai24 Oct 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1823/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Subramanian, Vs. The Income Tax Officer, 78, Co-Operative Colony, Vilankurichi, Ward 1(4), Coimbatore 641 035. Erode. [Pan:Cerps9236R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate (Virtual) ""थ" की ओर से/Respondent By : Ms. Samatha M. Mullamudi, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2013-14. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made Under Section 69A Of The Income Tax Act, 1961 [“Act” In Short] By The Assessing Officer.

For Appellant: Shri R. Sivaraman, Advocate (Virtual)For Respondent: Ms. Samatha M. Mullamudi, JCIT
Section 147Section 148Section 69A

give any explanation about the nature and source of total cash credits of ₹.6,62,229/-, the Assessing Officer treated the same as unexplained money under section 69A of the Act and added to the total income of the assessee. The ld. CIT(A) confirmed the addition made ... nature and source of total cash credit of ₹.6,62,229/- and added the same under section 69A of the Act on account of unexplained money. The ld. CIT(A) confirmed the same by recording his reasons vide para 7 of the impugned order. Further, it is noted at page