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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

Murlidhar Prasad, Patna vs. Assistant Commissioner of Income Tax, Patna

In the result, ITA Nos.233-235/PAT/2024, ITA Nos

ITA 273/PAT/2023[2015-16]Status: DisposedITAT Patna14 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita Nos.233, 234 & 235/Pat/2024 & Saroj Bala, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aaspb 3828 P & आयकर अपील सं/Ita No.267/Pat/24 & Ita Nos.279, 282 & 283/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2016-17 & 2018-19) & Cross Objection No.02/Pat/2023 (Arising Out Of Ita No.295/Pat/2023) (Assessment Year : 2012-2013) Lovely Rani Constructions Pvt Ltd Vs Acit, Circle-1, Patna 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita No.295/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13) Dcit, Central Circle-1, Patna Vs Lovely Rani Constructions Pvt Ltd 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita Nos.272, 273, 274, 275, 276 & 278/Pat/2023 (A.Yrs : 2014-15, 2015-16, 2016-17, 2017-18, 2019-20 & 2018-19) Murlidhar Prasad, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aekpp 1361 D

For Appellant: Shri Prince Chugh, ARFor Respondent: Shri Rajat Datta, CIT-DR
Section 132(1)Section 139(1)Section 142(1)Section 153ASection 153DSection 69A

assessment order vide order dated 24.08.2021 passed u/s.153A of the Act wherein an addition of Rs.7.00 lakhs was made by treating the same as unexplained money u/s.69A of the Act. 6. Aggrieved with the assessment order, the assessee filed an appeal before the ld.CIT(A) on legal issues as well

Murlidhar Prasad, Patna vs. Assistant Commissioner of Income Tax, Patna

In the result, ITA Nos.233-235/PAT/2024, ITA Nos

ITA 272/PAT/2023[2014-15]Status: DisposedITAT Patna14 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita Nos.233, 234 & 235/Pat/2024 & Saroj Bala, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aaspb 3828 P & आयकर अपील सं/Ita No.267/Pat/24 & Ita Nos.279, 282 & 283/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2016-17 & 2018-19) & Cross Objection No.02/Pat/2023 (Arising Out Of Ita No.295/Pat/2023) (Assessment Year : 2012-2013) Lovely Rani Constructions Pvt Ltd Vs Acit, Circle-1, Patna 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita No.295/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13) Dcit, Central Circle-1, Patna Vs Lovely Rani Constructions Pvt Ltd 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita Nos.272, 273, 274, 275, 276 & 278/Pat/2023 (A.Yrs : 2014-15, 2015-16, 2016-17, 2017-18, 2019-20 & 2018-19) Murlidhar Prasad, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aekpp 1361 D

For Appellant: Shri Prince Chugh, ARFor Respondent: Shri Rajat Datta, CIT-DR
Section 132(1)Section 139(1)Section 142(1)Section 153ASection 153DSection 69A

assessment order vide order dated 24.08.2021 passed u/s.153A of the Act wherein an addition of Rs.7.00 lakhs was made by treating the same as unexplained money u/s.69A of the Act. 6. Aggrieved with the assessment order, the assessee filed an appeal before the ld.CIT(A) on legal issues as well

Ambalal Gorakh Choudhari, Prakasha vs. Income Tax Officer, Ward-1, Dhule

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

ITA 1422/PUN/2025[2013-2014]Status: DisposedITAT Pune14 Oct 2025AY 2013-2014

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1422/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Ambalal Gorakh Choudhari Vs. Ito, Ward-1, Dhule. Legal Heir Anita Ambalal Chaudhari, Mukteshwar Mandir, At Post Prakasha, Taluka Shahada, Dist. Nandurbar- 425409. Pan : Afrpc1304D Appellant Respondent Assessee By : Shri Sandeep Rathi Revenue By : Shri Harshit Bari Date Of Hearing : 19.08.2025 Date Of Pronouncement : 14.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2025 Passed By Ld. Addl./Jcit(A)-2, Gurugram [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, Learned Assessing Officer & The Cit(A) Is Not Justified In Making/Confirming Additions Of Rs. 1020740/- To Returned Income U/S.69A Of The Act, As Said Section Is Applicable Only When In Any Financial Year The Assessee Is Found To Be Owner Of Any Money, Bullion, Jewellery Or Any Other

For Appellant: Shri Sandeep RathiFor Respondent: Shri Harshit Bari
Section 148Section 69A

satisfactory in the opinion of the ITO. In this case, appellant offered explanation of the source of credits to bank account. No any unexplained money, bullion or jewellery etc is in fact found by Ld. ITO as well as The CIT(A). So, in the absence of fulfillment of basic ... Assessing Officer and The CIT(A) are not justified in making/confirming additions of Rs. 1020740/- to returned income u/s.69A as section 69A says that unexplained money can be brought to tax if it is not recorded in books of accounts and assessee offers no explanation about nature and source

Chandrakant Krishna Pawar, Sangli vs. ITO Ward 4, Sangli

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

ITA 583/PUN/2025[2017-18]Status: DisposedITAT Pune13 Oct 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.583/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Chandrakant Krishna Pawar, Vs. Ito, Ward-4, Sangli. 2Nd Floor, Pawar Building, Sangliwadi, Tal. Miraj- 416416. Pan : Aaypp1161H Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 25.09.2025 Date Of Pronouncement : 13.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.05.2024 Passed By Ld. Addl./Jcit(A)-7, Kolkata [‘Ld.Cit(A)’] For The Assessment Year 2017-18. 2. There Is Delay Of 215 Days In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay Of 215 Days & Proceed To Adjudicate The Appeal.

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ramnath P. Murkunde
Section 142(1)Section 144Section 69A

determining the total income at Rs.12,34,660/-. The above assessed income includes an amount of Rs.4,22,600/- as unexplained money u/s 69A of the IT Act and an amount of Rs.7,82,058/- added as business income received in the shape of interest on capital and remuneration from

Sunil Govindlal Agrawal, Dhule vs. Income Tax Officer, Ward 1, Dhule

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

ITA 1958/PUN/2025[2014-15]Status: DisposedITAT Pune13 Oct 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1958/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Sunil Govindlal Agrawal, Vs. Ito, Ward-1, Dhule. 2827B, Lane No.4, Khol Galli Dhule- 424001. Pan : Aavpa1816F Appellant Respondent Assessee By : Shri Sharad A. Shah Revenue By : Shri Manishkumar Sinha Date Of Hearing : 18.09.2025 Date Of Pronouncement : 13.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. There Is Delay Of 262 Days In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing

For Appellant: Shri Sharad A. ShahFor Respondent: Shri Manishkumar Sinha
Section 142(1)Section 147Section 148Section 250(6)Section 69A

were issued to the assessee & it was asked as to why deposit of Rs.82,73,500/- made by him should not be treated as unexplained money u/s 69A of the IT Act. To this notice there was no compliance. Ld. Assessing Officer concluded the assessment proceedings by bringing ... cash credits of Rs.82,73,500/- as unexplained money u/s 69A of the IT Act. The assessment was completed u/s 147 r.w.s. 144 r.w.s. 144B of the IT Act on a total income of Rs.84,88,760/- as against the income returned by the assessee at Rs.2