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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

Income Tax Officer, New Delhi vs. Satish Kumar, New Delhi

ITA 2447/DEL/2024[2017-18]Status: DisposedITAT Delhi26 Sept 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2447/Del/2024 निर्धारणवर्ष/Assessment Year: 2017-18 Income Tax Officer, Room No.217, 2Nd Floor, Vikas Bhawan, New Delhi. बनाम Vs. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Revenue By सुनवाईकीतारीख / Date Of Hearing: उद्घोषणाकीतारीख /Pronouncement On Satish Kumar X/1585, Rajgarh Colony, New Delhi. Pan No.Aнерк4309В Shri Pramod Jain, Ca & Shri Mukul Gupta, Adv. Shri Manish Gupta, Sr. Dr 19.08.2025 26.09.2025 आदेश /Order Per C.N. Prasad, J.M. This Appeal Is Filed By The Revenue Against The Order Of The Ld. Cit(Appeals), Nfac, Delhi Dated 26.03.2024 For The Ay 2017-18 In Deleting The Addition Made U/S 68 Of The Act In Respect Of Cash Deposits Made During Demonetization Period. 2. Ld. Dr Made The Following Submissions: (I) The Assessee Is An Individual Engaged In The Trading Of Ghee & Oil Under The Proprietorship M/S Phool Chand Hari Kishan. He Filed His Return Of Income On 26.10.2017 Declaring Total Income Of Rs.4,58,120/- For The

Section 115BSection 68

demonetized notes after 8.11.2016 in violation of the notifications issued by RBL. Accordingly, he has taken the view that the above said amounts represents unexplained money of the assessee. I am unable to understand the rationale in the view taken by A.O. I noticed that the AO has invoked

Saraswati Shishu Mandir Parichalana Samiti, Hatiatangar vs. ITO Exemption, Cuttack

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

ITA 445/CTK/2025[2017-18]Status: DisposedITAT Cuttack25 Sept 2025AY 2017-18

Bench: Shri George Mathanआयकर अपील सं/Ita No.445/Ctk/2025 (िनधा"रण वष" / Assessment Year : 2017-2018) Saraswati Shishu Mandir Vs Ito (Exemption), Cuttack Parichalana Samiti, Hati Nagar, Kendujhargarh, Kendujhar Sadar, Kendujhar 758001 Pan No. : Aajas 6194 B (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती क" ओर से /Assessee By : Shri Dr. Sanjay Behura & Ananta Narayan Singhbabu, Ars राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. D.R सुनवाई क" तारीख / Date Of Hearing : 25/09/2025 घोषणा क" तारीख/Date Of Pronouncement : 25/09/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Ld. Addl/Jcit (A)-1,Nashik Order Dated 05/06/2025 Passed In Appeal No.Cit(A),Cuttack/10525/2019-20 For The Assessment Year 2017-2018. 2. It Was Submitted By The Ld. Ar That The Assessee Is Running An Educational Institution In Kendujhar. It Was The Submission That The During The Demonetization Period The Assessee Had Deposited Rs.11,33,280/- In Cash In His Bank Account. It Was Further Submission That The Sbn Deposited During The Demonetization Period Was To An Extent Of Rs.4,98,500/-. It Was The Further Submission That The Assessee Had Total Receipts Of Rs.1,54,00,000/-. It Was The Submission That The Ao Did Not Accept The Contentions Of The Assessee In Respect Of The Demonized

For Appellant: Shri Dr. Sanjay BehuraFor Respondent: Shri Vijay Singh, Sr. D.R

accept the contentions of the assessee in respect of the demonized 2 currency deposited in the bank account and has stated the same as unexplained money in the hands of the assessee. It was the submission that he had no objection if the issue is restored to the file

Income Tax Officer 1(1)(1), Kanpur vs. Ajay Kumar Gupta, Kanpur

In the result, ITA No.427/LKW/2024 is allowed for statistical purposes while CO No

ITA 427/LKW/2024[2017-18]Status: DisposedITAT Lucknow25 Sept 2025AY 2017-18

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2017-18 Income Tax Officer-1(1)(1), Vs. Ajay Kumar Gupta, Kanpur, U.P. 51/92C, Naya Ganj, Kanpur Pan: Abkpg5651J (Appellant) (Respondent) C.O. No.26/Lkw/2024 In A.Y. 2017-18 Ajay Kumar Gupta, Vs. Income Tax Officer-1(1)(1), 51/92C, Naya Ganj, Kanpur Kanpur, U.P. Pan: Abkpg5651J (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 25.09.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Appeal & Cross Objection Have Been Filed By The Revenue & The Assessee Respectively, Against The Orders Of The Ld. Cit, Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 10.05.2024, Wherein The Ld. Cit(A) Has Allowed The Appeal Of The Assessee Against The Orders Of The Ao Under Section 147 R.W.S. 144 Passed On 30.03.2022. The Grounds Of Appeal Are As Under:- “1. Ld. Commissioner Of Income Tax (Appeal) Has Erred In Law & On Facts In Accepting The Contention Of The Assessee That The Proceedings Made U/S 147 Is Not In Accordance With Law. 2. Ld. Commissioner Of Income Tax (Appeal) Has Erred In Law & On Facts In Deleting The Addition Made By The Ao On Account Of Unexplained Money U/S 69A Of Income Tax Act, 1961 Deposited During The F.Y.2016-17 Without Appreciating That The Ao Has 1 Co No.26/Lkw/2024 Ajay Kumar Gupta A.Y. 2017-18

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 142(1)Section 144Section 144BSection 147Section 148Section 250Section 69A

Commissioner of Income Tax (Appeal) has erred in law and on facts in deleting the addition made by the AO on account of unexplained money u/s 69A of Income Tax Act, 1961 deposited during the F.Y.2016-17 without appreciating that the AO has 1 CO No.26/LKW/2024 Ajay Kumar Gupta