“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

Dipak Chhaganlal Naik L/H Amitaben Dipak Naik, Surat vs. ITO, Ward 2(3)(1), Surat

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

ITA 1118/SRT/2024[2013-14]Status: DisposedITAT Surat17 Oct 2025AY 2013-14

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1118/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Dipak Chhaganlal Naik Income Tax Officer Ward-2(3)(1), बनाम/ L/H Amitaben Dipak Naik Surat, Room No. 627, Aaykar Vs. 44, China Gate-2, B/Hgayatri Bhawan, Majura Gate, Surat-395 Mandir, Althan S.O, Althan, 001 Surat- 395 017 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadhn 5872 L (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Rajesh Upadhyay, Ar राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 28/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 17/10/2025

Section 144Section 148Section 148ASection 2(47)Section 250Section 50CSection 80C

Delhi has erred in law and on fact to uphold addition of Rs.79,400/- made by the assessment unit by treating agricultural income as unexplained money earned by the appellant, without specifying any section of Income-tax Act. 6. Ld. CIT(A), NFAC, Delhi has erred

Raghunath Narayan Dhote, Nagpur vs. ITO Ward 1(2), Nagpur

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

ITA 505/NAG/2025[2018-2019]Status: DisposedITAT Nagpur17 Oct 2025AY 2018-2019

Bench: Shri Pavan Kumar Gadale

For Appellant: Shri.Naresh Jakhotia.A.RFor Respondent: Shri.Surjit Kumar Saha.Sr.DR

Section 56(2)(x)Section 69A

assessment order and rejected the assesses contentions and sources could not be explained and made addition of cash deposits of Rs.26,00,000/- as unexplained money u/sec69A of the Act. On the second disputed issue, the Assessing Officer found that the assessee has mentioned in the sale deed payment

Ashutosh Deshpande, Nagpur vs. ACIT/DCIT Circle -5, Nagpur

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

ITA 493/NAG/2025[2017-18]Status: DisposedITAT Nagpur17 Oct 2025AY 2017-18

Bench: Shri Pavan Kumar Gadaleashutosh Sudhakar Deshpande, Plot No.5, Gandhi Nagar, Nagpur 440 010, ……………. Appellant Maharashtra. Pan–Aavpd0098E V/S Acit Circle–5, ……………. Respondent Nagpur-440006, Maharashtra. Assessee By: Shri.Ashutosh Sudhakar Despande. Revenue By : Shri.Surjit Kumar Saha.Sr.Dr

For Appellant: Shri.Ashutosh Sudhakar DespandeFor Respondent: Shri.Surjit Kumar Saha.Sr.DR

Section 251(1)(a)Section 69A

erred in sustaining the action of Ld. AO towards addition of cash deposit of Rs. 13,28,500/- during the demonetization period as Unexplained Money u/s. 69A while charging only profit element for the rest of the cash deposit. The Ld. AO & CIT(A) could instead of 2 Ashutosh sudhakar

Income Tax Officer, Tenali vs. Suryaprakasarao Kanaparthy, Bethapudi, Repalle

In the result, the Cross Objection filed by the assessee is allowed in terms of our aforesaid observations, while for the appeal filed by the revenue having been rendered as academic in nature, is ...

ITA 239/VIZ/2025[2018]Status: DisposedITAT Visakhapatnam17 Oct 2025

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.239/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Income Tax Officer, Vs. Suryaprakasarao Tenali. Kanaparthy, Bethapudi, Repalle, Bapatla. Pan: Dmqpk7509P (Appellant) (Respondent)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 147Section 148Section 148ASection 151Section 151ASection 69A

deposits based on supporting documentary evidence, thus, held the amount of Rs. 1,12,13,930/- (supra) as having been sourced out of his unexplained money under section 69A of the Act. 9. Aggrieved, the assessee carried the matter in appeal before the CIT(A), who concurred with the explanation

Shri Vinay Pratap Singh, Lucknow vs. Astt. Commissioner of Income Tax, Lucknow

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

ITA 688/LKW/2015[2012-13]Status: DisposedITAT Lucknow17 Oct 2025AY 2012-13

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Swarn Singh, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR

Section 132Section 143(3)Section 153CSection 153D

portion of sale was being done in cash. Therefore, such cash sale which is also incorporated in books of accounts cannot be treated as unexplained money. The addition made by the Ld AO amounted to double addition as the Cash Sales has already been entered into books of accounts

Mikal Bhupendrabhai Patel, Petlad vs. I.T.O Ward 1(3)(1), Petlad

Accordingly, the appeal filed by the assessee is dismissed

ITA 474/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Jainish Parikh, CAFor Respondent: Shri Abhijit, Sr. DR

Section 139Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

cash deposits of Rs. 17,16,245/- and other credit entries aggregating to Rs. 28,10,000/- in the IndusInd Bank account as unexplained money under section 69A of the Act and added the total sum of Rs. 53,15,500/- to the total ITA Nos. 473&474/Ahd/2025 Mikal Bhupendrabhai

Mikal Bhupendrabhai Patel, Petlad vs. I.T.O Ward 1(3)(1), Petlad

Accordingly, the appeal filed by the assessee is dismissed

ITA 473/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Jainish Parikh, CAFor Respondent: Shri Abhijit, Sr. DR

Section 139Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

M/S. 9Th Street Architects, Ahmedabad vs. The Dy.CIT, Circle-4(1)(1), Ahmedabad

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

ITA 1463/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Divatia & Shri Samir Vora, ARsFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 133ASection 154Section 250Section 69A

illegal, unlawful, and without jurisdiction. It was submitted that the question whether income disclosed during survey should be treated as business income or as unexplained money under section 69A was a highly debatable issue involving interpretation of law and hence, beyond the purview of section 154. The assessee argued that ... business turnover in the regular return of income. The Assessing Officer, however, considered that the said amount ought to have been assessed as unexplained money under section 69A, taxable under section 115BBE, and accordingly invoked section 154 of the Act on the ground of a mistake apparent from record

Spandana Sphoorty Financial Limited, Hyderabad vs. ACIT., Circle 3(2), Hyderabad

ITA 821/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18

Section 143(3)Section 145Section 69A

underlying the notification. Accordingly, the A.O held the amount of cash deposits (SBN's) of Rs.56.41 crores (supra) as having been sourced from the unexplained money of the assessee company under section 69A of the Act. 5. Apart from that, the A.O. observed that the assessee company had, during ... addition of the cash deposits (SBN's) made in bank accounts by treating the same as having been sourced out of the assessee's unexplained money under Section 69A of the Act: Rs.56,41,00,000/-; and (ii) addition on account of deviation in accounting treatment

Kiran Reddy Muddasani, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, ITA.No.1157/Hyd

ITA 1158/HYD/2025[2012-13]Status: DisposedITAT Hyderabad17 Oct 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1157 & 1158/Hyd./2025 िनधा"रण वष"/Assessment Year 2012-2013 Kiran Reddy Muddasani, The Income Tax Officer, Hyderabad – 500 035. Ward-9(3), Vs. Telangana. Hyderabad – 500 004. Pan Bftpm6705H Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri P. Vinod, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 17.10.2025 आदेश/Order Per Vijay Pal Rao: These Two Appeals Ita Nos.1157 & 1158/Hyd./2025 By The Assessee Are Directed Against The Two Separate Orders Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac”], Delhi, Both Dated 26.05.2025 Arising From Assessment Order Passed U/Sec.147 R.W.S.144 Of The Income

For Appellant: Sri P. Vinod, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 147Section 148Section 271(1)(c)

account. Thus, learned DR has submitted that the Assessing Officer has rightly made the addition by taking the deposits in the bank account as unexplained money of the assessee u/sec.69A of the Income Tax Act, 1961. He has relied upon the orders of the authorities below. 6. We have considered ... passed the best Judgment assessment order u/sec.144 r.w.s.147 of the Income Tax Act, 1961, whereby the deposit in the bank account was assessed as unexplained money u/sec.69A of the Income Tax Act, 1961. Before the learned CIT(A), the assessee explained that the assessee has been regularly filing the return

Kiran Reddy Muddasani, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, ITA.No.1157/Hyd

ITA 1157/HYD/2025[2012-13]Status: DisposedITAT Hyderabad17 Oct 2025AY 2012-13

For Appellant: Sri P. Vinod, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 147Section 148Section 271(1)(c)

Khukurdaha Jagannathpur Samabay Krishi Unnayan Samity Ltd., Paschim Medinipur vs. I.T.O., Circle - 38, Paschim Medinipur

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

ITA 1815/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Oct 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Khukurdaha Jagannathpur Samabay Krishi Unnayan Samity Ltd……………….…..………….……………………….……….……….……Appellant Paschim Medinipur, Ghatal, Daspur-Ii, W.B- 721641.. [Pan: Aadak3947N] Vs. Ito, Ward-38, Midnapur.……………………………….....……...…..…..Respondent Appearances By: Shri J. M. Thard, Advocate, Appeared On Behalf Of The Appellant. Shri Pradip Kr. Biswas, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 10.06.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 143(2)Section 250Section 69ASection 80P

deposited by the assessee in bank during demonetization period. The Assessing Officer treated the said amount of Rs.79,80,000/- as unexplained money Khukurdaha Jagannathpur Samabay Krishi Unnayan Samity Ltd u/s 69A of the Act and added the same to the total income of the assessee. 3. Aggrieved

M.A. Financial Services Pvt. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1272/KOL/2025[2015-2016]Status: DisposedITAT Kolkata17 Oct 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthiassessment Year: 2015-16 M. A Financial Services Pvt. Ltd.……………………….……….……….……Appellant 2, Lal Bazaar Street, 1St Floor, Kol-700001.. [Pan: Aaccm0481E] Vs. Ito, Ward-4(1), Kolkata…….…………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Of The Assessee Are That The Assessee Filed Its Return Of Income For The A.Y 2015-16 U/S 139 Of The Act On 20.07.2015 Declaring Total Income Of Rs.9,647/-. The Said Return Was Processed U/S 143(1) Of The Act. Later On, Based On Information Received Through Itba Software Under The Head High Risk Transaction Case Notice U/S 148A(B) Of The Act Was Issued & Finally Notice U/S 148 Of The Act Was Issued On 13.07.2022. In Response, The Assessee Filed Return On 02.11.2021 Declaring Total Income Of Rs.9,647. Assessment Was Made Under Sec. 147 M. A Financial Services Pvt. Ltd Read With Section 144B Of The Act On 24.05.2023 Determining Total Income Of Rs.6,55,31,471/- Inter-Alia Making Following Addition:

Section 139Section 143(1)Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 250Section 69A

144B of the Act on 24.05.2023 determining total income of Rs.6,55,31,471/- inter-alia making following addition: 1. Addition on account of unexplained money of Rs.5,18,51,321/-. u/s. 69A of the Act. 2. Disallowance of expenses claimed under the head of salary and wages of Rs.51 ... Addition on account of unexplained money of Rs.85,55,000 u/s. 69A of the Act. 3. Aggrieved by the said order, the assessee preferred appeal before the ld. CIT(A) wherein the appeal of the assessee has been dismissed on account of non-compliance. 4. Being aggrieved and dissatisfied

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

3012/Mum/2025

ITA 3936/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Section 132Section 132(4)Section 69A

worth of the statements recorded under section 132(4), and the consequential additions under various heads, particularly capital gains on alleged NOC receipts and unexplained money under section 69A of the Act. 3. Brief facts as culled out from the records are that the assessee, The Estate Investment Company ... Assessing Officer bifurcated the entries into two broad categories those treated as capital receipts exigible to capital gains tax and others treated as unexplained money under section 69A. Accordingly, ld. AO made following additions:- i. Rs.5,97,13,000 treated as unaccounted capital gains on account of NOC amount received

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

ITA 3928/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16

Section 132Section 132(4)Section 69A

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3228/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16

Section 132Section 132(4)Section 69A

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3227/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

worth of the statements recorded under section 132(4), and the consequential additions under various heads, particularly capital gains on alleged NOC receipts and unexplained money under section 69A of the Act. 3. Brief facts as culled out from the records are that the assessee, The Estate Investment Company ... Assessing Officer bifurcated the entries into two broad categories those treated as capital receipts exigible to capital gains tax and others treated as unexplained money under section 69A. Accordingly, ld. AO made following additions:- i. Rs. 5,97,13,000 treated as unaccounted capital gains on account of NOC amount

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3225/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Oct 2025AY 2019-20

Section 132Section 132(4)Section 69A

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3224/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Oct 2025AY 2020-21

Section 132Section 132(4)Section 69A

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3012/Mum/2025

ITA 3223/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Oct 2025AY 2021-22

Section 132Section 132(4)Section 69A