← All Phrases

“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

Ketkiben Samirbhai Jani, Junagadh vs. ITO, Ward-1, Junagadh

ITA 544/RJT/2025[2019-20]Status: DisposedITAT Rajkot23 Oct 2025AY 2019-20

Bench: Dr. Arjun Lal Sainiआयकर अपीलसं./Ita No.544/Rjt/2025 निर्धारणवर्ष / Assessment Year: (2019-20) (Hybrid Hearing) Ketkiben Samirbhai Jani 11/12 Vs. Ito, Ward-1 Chamber Building,, Jaishree Talkies Road, Near Sardar Patel Bhavan, Junagadh. 362001, Bhoothnath Chambers, College Road, Junagadh 362001 स्थायी लेखासं./जीआइआरसं./Pan/Gir No.: Abupj1530B (Appellant) (Respondent) Appellant By : Shri Samir Jani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 18/09/2025 Date Of Pronouncement : 23/10/2025 आदेश / Order Per, Dr. Arjun Lal Saini Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2019-20, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 18/08/2025, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 21/03/2024, U/S 147 Of The Income Tax Act, 1961. Page 1

For Appellant: Shri Samir Jani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 132Section 147Section 148Section 250Section 69A

held that assessing officer has rightly invoked the provisions of section 69A and treated the cash payment of Rs. 1,68,667/- as unexplained money, being the assessee's share of the unaccounted on-money paid towards the purchase of immovable property. Feeling aggrieved by the order

Primula Bhandari, Gangtok vs. DCIT, Circle 3(2), Gangtok

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

ITA 1394/KOL/2025[2018-2019]Status: DisposedITAT Kolkata23 Oct 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraआयकर अपील सं/Ita No.1394/Kol/2025 (नििाारण वर्ा / Assessment Year : 2018-2019) Primula Bhandari Vs Dcit, Circle-3(2), Kolkata C/O Subash Agarwal & Associates, 1, Gibson Lane, Suite 213, Kol-69. Pan No. :Ajvpb2150Q (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Smt. Parna Datta, Advocate राजस्व की ओर से /Revenue By : Shri Sanjib Kumar Paul, Sr. Dr सुिवाई की तारीख / Date Of Hearing : 22/10/2025 घोर्णा की तारीख/Date Of Pronouncement : 23/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : This Is An Appeal Filed By The Assessee Against The Order Of The Nfac Dated 06.05.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Did Not File The Return Of Income For The Relevant Assessment Year. The Assessing Officer Noticed Cash Deposits In The Bank Account Of The Assessee & Accordingly Reopened The Assessment Under Section 147 Of The Income-Tax Act, 1961.The Assessment Was Completed Under Sections 144/147, Determining The Total Income At ₹25,85,346/-, After Making An Addition Of ₹25,85,346/- Under Section 69A Of The Act On Account Of Unexplained Money.

For Appellant: Smt. Parna Datta, AdvocateFor Respondent: Shri Sanjib Kumar Paul, Sr. DR
Section 10Section 147Section 250Section 69A

total income at ₹25,85,346/-, after making an addition of ₹25,85,346/- under section 69A of the Act on account of unexplained money. 2 Primula Bhandari 3. Aggrieved by the said assessment, the assessee preferred an appeal before the CIT(A), who confirmed the addition. Hence, the assessee

Mr.Mohamed Meera Wahitha, Sivagangai vs. ACIT, Circle-1, Karaikudi

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

ITA 1955/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Oct 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. No.1955/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Mohamed Meera Wahitha, Vs. The Assistant Commissioner Of 13-3/12-H, Bungalow Oorani Street, Income Tax, Puduvayal, Karaikudi Taluk, Circle 1, Sivagangai 630 108. Karaikudi. [Pan:Aajpw6483G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri M.K. Rangasamy, C.A. ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.09.2025 घोषणा की तारीख /Date Of Pronouncement : 22.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 10 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 By The Assessing Officer

For Appellant: Shri M.K. Rangasamy, C.AFor Respondent: Ms. E. Pavuna Sundari, Addl. CIT
Section 131Section 133ASection 44ASection 69Section 69A

notes during the period of demonetization, the cash deposited during 10.11.2016 to 30.12.2016 to an extent of ₹.3,14,15,030/- is treated as unexplained money and added to the total income of the assessee. The ld. CIT(A) confirmed the addition made by the Assessing Officer. 3 I.T.A. No.1955/Chny/25 ... addition u/s.69 or 69A of the Act. Because, the mandate of the provisions of Section 69 & 69A of the Act, i.e., unexplained investments and unexplained money etc., may be deemed to be the income of the assessee for the financial year relevant to assessment year concerned, in which the assessee

Keshram, Village- Patwari vs. The ITO Ward- 5(2)(1), G Budh Nagar, Gautam Budh Nagar

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

ITA 2158/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Oct 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.2158/िद"ी/2024(िन.व. 2017-18) Keshram Through Legal Heir Shri Sunder Singh, Village Patwari Bisrakh, Gatam Buddha Nagar, Uttar Pradesh 203207 ...... अपीलाथ"/Appellant Pan : Bqgpk-1567-D बनाम Vs. Income Tax Officer, Ward -5(2)(1), Gatam Buddha Nagar, ..... "ितवादी/Respondent Uttar Pradesh 201303 अपीलाथ" "ारा/ Appellant By : None "ितवादी"ारा/Respondent By : Shri Om Prakash, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 24/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 24/07/2025 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 10.01.2024, For Assessment Year 2017-18. 2. The Appeal Is Time Barred By 53 Days. The Assessee Has Filed A Petition For Condonation Of Delay Supported By An Affidavit. After Perusal Of Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, But Is For The Reasons

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr. DR
Section 139Section 142(1)Section 144Section 69A

compliance by the assessee. Consequently, the AO framed assessment u/s 144 of the Act, treating total sum of Rs.72,21,995/- as unexplained money u/s 69A of the Act. Aggrieved, the assessee filed appeal before the CIT(A), but remained unsuccessful. Hence, the present appeal. 4. Shri Om Prakash, representing