← 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

Jitendra Singh, Bijnor vs. Income Tax Officer, Bijnor

In the result, the Assessee’s appeal is allowed

ITA 3316/DEL/2025[2015-16]Status: DisposedITAT Delhi03 Oct 2025AY 2015-16

Bench: Shri Mahavir Singhasstt. Year : 2015-16 Jitendra Singh, Vs. Acit/Jcit(Appeals) C/O S R Agarwalla & Co., Ca Faridabad / Nfac Shop No. 7, Kisan Inter College Market, Meerut-Karnal Road, Shamli, Uttar Pradesh-246776 (Pan: Ezaps4872M) (Appellant) (Respondent) Appellant By : Sh. Manish Singh, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr. Date Of Hearing 09.09.2025 Date Of Pronouncement 03.10.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Addl/Jcit (A), Faridabad Dated 27.03.2025 Pertaining To Assessment Year 2015-16 On The Solitary Issue Of Addition Of Rs. 13,00,000/- On Account Of Cash Deposit. 2. Heard Both The Sides & Perused The Records. 3. Brief Facts Of The Case Are That The Information Reported In Aims Module Of Itba That The Assessee Had Deposited More Than Rs. 10 Lacs In Different Saving Bank Accounts Maintained By Him During The F.Y. 2014-15 Relevant To Ay 2015-16. A Query Letter As Well As A Notice U/S. 133(6) Of The Income Tax Act, 1961 Was Issued & Served Upon The Assessee Asking Him To Furnish The Source Of Income & Credit

For Appellant: Sh. Manish Singh, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 147Section 69A

cash deposit in his bank account, the addition of Rs. 2 | P a g e 13,00,000/- was sustained on account of unexplained money by the AO. Aggrieved, the action of the Ld. CIT(A), assessee is in appeal before the Tribunal. 4. Heard the rival contentions and perused ... income based on information regarding cash deposits in the Appellant's bank account. In the assessment order, the AO treated these cash deposits as unexplained money under Section 69A of the Act, without adequately considering the Appellant's submissions and evidence. The Assesse duly explained during the assessment proceedings that

Jagveer Singh, Banda vs. Income Tax Officer Ward-1, Satna

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

ITA 11/JAB/2025[2018-19]Status: DisposedITAT Jabalpur30 Sept 2025AY 2018-19

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Jagveer Singh, Vs. Income Tax Officer, Village Bhiyamau Khohi Thana, Ward-1, Satna Baraunda, Satna, M.P. Pan:Eneps0024R (Appellant) (Respondent) Assessee By: Sh. Dhiraj Ghai, C.A. Revenue By: Sh. N.M. Prasad, Sr. Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 30.09.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Dismissing The Appeal Of The Assessee Against The Orders Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 144 Of The Income Tax Act On 20.03.2023. The Grounds Of Appeal Are As Under:- “1. The Ex-Party Order Passed U/S Rs. 144 For Ay 2018-19 On 20.03.2023 By Faceless Centre Holding Cash Deposits To The Extent Of Rs. 1,76,85,400/-Deposited In Bank Accounts As Unexplained Cash & Thereby Making Addition Of 1,76,85,400/- Is Wholly Illegal, Unlawful & Against The Principles Of Natural Justice. 2. The Ex-Party Order Of Learned Cit(A) Is Bad In Law & Liable To Be Quashed For Non Consideration Of Material On Record & Additions Made Of Rs 1,76,85,400/- Is Illegal In Want Of Non-Application Of Principles Of Natural Justice 3. Without Prejudice:-The Learned Commissioner Of Income Tax (Appeals) Has Erred In Dismissing The Appeal Ex-Party & Thereby Confirming The Order Passed By Assessing Officer. The Ex-Party Order Passed By Learned Assessing Officer Being Bad In Law & Void-Ab-Inito Was Required To Be Quashed Instead Of Being Confirmed

For Appellant: Sh. Dhiraj Ghai, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 147

accordingly, he added back the cash deposit of Rs. 1,76,85,400/-, that had been made in the accounts of the assessee, as unexplained money under section 69A. 4. Aggrieved with the said orders, the assessee filed an appeal with the National Faceless Appeal Centre. Here

Shri Sanjay Gordhandas Vaja, Ahmedabad vs. The ITO, International Taxation, Gandhidham-Kutch

In the result, this appeal of the assessee is allowed

ITA 89/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Sept 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.89/Rjt/2024 Assessment Year: 2018-19 Sanjay Gordhandas Vaja Income Tax Officer Int. 202, Harmony Heights, Capital Road, बनाम Tax), Gandhidham, Income- Science City, Ahmedabad-380 060 Tax Office, Amruta Estate /Vs. Building, Nr. Girnar Cinema, M.G. Road, Rajkot-360 001 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Ahtpv 3289 L (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Aseem Takkar, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 31/07/2025 घोषणा क" तार"ख /Date Of Pronouncement : 30/09/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2018-19, Is Directed Against The Final Order Passed By The Assessing Officer, (After Incorporating Findings Of Dispute Resolution Panel-2 Mumbai, Dated 29.12.2023), Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) .

For Appellant: Shri Aseem Takkar, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 115BSection 144CSection 147Section 148Section 148ASection 68Section 69

Thane. 7. The Learned Assessing Officer has erred in making addition of Rs.95,222/- treating the deposits in HDFC Bank account as alleged unexplained money u/ 69A of the I.T. Act, 1961 only on the basis of order dtd. 29/12/2023 passed by the Hon’ble DRP, Mumbai. 8. The assessee ... addition on account of Purchase of Immovable Property, Rs.32,50,000/-. The assessing officer also made addition of Rs.4,03,914/- on account of unexplained money under section 69A of the Act, which was rectified by the honourable DRP to Rs.95,222/-instead of Rs.4,03,914/-. 10.Aggrieved