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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

Mohammad Habeeb Uddin, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 8/HYD/2025[2017-18]Status: DisposedITAT Hyderabad08 Oct 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.08/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Mohammad Habeeb Uddin, Vs. Income Tax Officer, 11-2-323-Cross Bazaar, Ward-7(1), Ghat, Hyderabad, Hyderabad. Telangana – 500004. Pan: Aaqph8462F (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Rajesh Vaishnav, Ca राज" व "ारा/Revenue By: Sri Posu Babu Alli, Sr. Ar सुनवाई की तारीख/Date Of 20/08/2025 Hearing: घोषणा की तारीख/Date Of 08/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Cit(Appeals), Nfac, Dated 30.12.2019 For The Assessment Year 2017-18. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Sri Rajesh Vaishnav, CAFor Respondent: Sri Posu Babu Alli, Sr. AR
Section 115BSection 133ASection 234ASection 271ASection 69A

documentary evidence submitted by the Appellant. 3. The Hon'ble CIT(A) erred in treating the deposit of Specified Bank Notes (SBNs) as an unexplained money us 69A and taxing under the provisions of Section 115BBE of the Act without considering the legal arguments and factual evidence submitted ... demonetisation period, i.e., on 08.11.2016, held the balance cash deposits of Rs. 88,17,000/- as having been sourced out of his unexplained money U/s 69A, of the Act. 5. Aggrieved, the assessee carried the matter in appeal before the CIT(A). The CIT(A) found no infirmity

Srinivasarao Kolasani, Hyderabad vs. ITO., Ward-9(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 433/HYD/2025[2017-18]Status: HeardITAT Hyderabad08 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Raoआ.अपी.सं /Ita No.433/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Srinivasa Rao Kolasani, Income Tax Officer, Vs. Hyderabad. Ward 9(1), Pan: Ahwpk6333P Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Snsr Chinmai, Adv. रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Dr सुिवधई की तधरीख/Date Of Hearing: 06/10/2025 घोर्णध की तधरीख/Pronouncement: 08/10/2025 आदेश/Order Per Inturi Rama Rao : This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 26.10.2023 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is An Individual. The Return Of Income For The A.Y. 2017-18 Was Filed On 15.02.2019 Declaring Total Income Of Rs.4,76,020/-. The Assessing Officer Completed The Assessment Vide Order Dated 21.12.2019 Passed U/S.143(3) Of The Income Tax Act, 1961 (“The

For Appellant: SNSR Chinmai, AdvFor Respondent: Dr. Sachin Kumar, DR
Section 143(3)Section 250(6)

While doing so, the Assessing Officer made addition of cash deposited in the bank account during demonetization period of Rs.30,54,255/- as unexplained money as the assessee failed to explain the sources of cash deposits with supporting evidences. 3. Being aggrieved by the order of Assessing Officer, the assessee