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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

Priyanka, New Delhi vs. Income Tax Officer, Ward 50(3), Delhi

Appeal is allowed

ITA 4665/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Priyanka Vs. Ito, Ward 50(3), Block 5/25, Old Rajinder Nagar, Delhi New Delhi (Pan: Avnpp5108Q) (Appellant) (Respondent) Appellant By : Ms. Meenal Goyal, Ca & Sh. Abhinav Jain, Adv. Respondent By : Shri Manoj Kumar, Sr. Dr. Date Of Hearing 04.09.2025 Date Of Pronouncement 24.09.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Nfac, Delhi Dated 26.07.2025 On The Solitary Ground Relating To Sustaining The Addition Of Rs. 30,65,000/- Made By The Ao U/S. 69A Of The Act. 2. Brief Facts Of The Case Are That Assessee Filed Its Return Of Income For The Assessment Year 2017-18 On 31.10.2017 Declaring A Total Income Of Rs. 3,23,910/-. Subsequently, The Case Was Selected For Scrutiny & Notices U/S. 143(2) & 142(1) Of The Act Were Issued & Served. The Reasons For Selection Of The Case For Scrutiny Were, “Abnormal Increase In Cash Deposits During Demonetization Period & High Value Receipt Of Cash Shown From Third Parties In Response Data”. The Assessee Was Found To Have Deposited Cash Of Rs. 30,65,000/- During The Demonetization Period In Fy 2016-17 In Her Bank Account Maintained With The Punjab National Bank. The Assessee Claimed That The Said Cash Was Received By Her

For Appellant: Ms. Meenal Goyal, CA & Sh. Abhinav Jain, AdvFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115BSection 143(2)Section 143(3)Section 69A

sources of the cash such deposits. Hence, he made the addition of Rs. 30,65,000/- u/s. 69A of the Act as unexplained money and completed the assessment u/s. 143(3) of the Act on 26.12.2019 at Rs. 33,88,910/- and the same was taxed u/s. 115BBE @ 60%. However

Subashini Sood, South Delhi vs. DCIT, New Delhi

Appeal is partly allowed in the aforesaid terms

ITA 4077/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Subashini Sood, Vs. Dcit, New Delhi C-251, 6Th Floor, Defence Colony, New Delhi – 110 024 (Pan: Ajsp8300A) (Appellant) (Respondent) Appellant By : Ms. Agni Choudhary, Adv. & Sh. Raghav Sharma, Ca (Thru Vc) & Sh. Rahul Agarwal, Ca Respondent By : Shri Manoj Kumar, Sr. Dr. Date Of Hearing 04.09.2025 Date Of Pronouncement 24.09.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Addl/Jcit(A)-2 Noida Dated 05.10.2024 On The Solitary Ground Relating To Sustaining The Addition Of Rs. 11,47,000/- Made By The Ao U/S. 69A Of The Act By Treating The Cash Deposit As Unexplained Investment. 2. Brief Facts Of The Case Are That Assessee Filed Her Return Of Income On 23.10.2017, Declaring A Total Income Of Rs. 2,72,210/-. During The Course Of Scrutiny Assessment, The Ao Found That The Assessee Had Deposited Rs. 11,47,000/- In Her Bank Account During The Demonetization Period, Specifically Between

For Appellant: Ms. Agni Choudhary, Adv. & Sh. RaghavFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115Section 115BSection 69A

November and December 2016. The AO, not being satisfied with the explanation provided regarding the source of cash deposits, treated the entire amount as unexplained money and added it to the total income of the assessee under section 69A of the Act. Consequently, the total income was enhanced

Bhim Singh, Jaipur vs. I.T.O, Ward 4(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 740/JPR/2025[A.Y. 2017-18]Status: DisposedITAT Jaipur23 Sept 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No.740/JPR/2025 निर्धारण वर्ष/Assessment Year : 2017-18 Shri Bhim Singh C-24, Ambabari Metal Colony Jaipur - 302 023 बनाम Vs. The ITO Ward 4(1) Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: CFRPS 5909A अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by : Shri G.M. Mehta, CA राजस्व की ओर से / Revenue by: Shri Gautam Singh Choudhary, JCIT-DR सुनवाई की तारीख / Date of He

For Appellant: Shri G.M. Mehta, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR
Section 145(3)Section 250Section 69A

bank deposits of SBN whereas on source of money could not be subject matter of application of provisions of Sec. 69A (unexplained money etc.) 2.1 Apropos to the grounds of appeal of the assessee, it is noticed that the ld. CIT(A) has dismissed the appeal of the assessee ... returns filed and alsodoes not commensurate with the income profile. Thus, I find that the AO was justified in treating the cash deposits as unexplained money u/s 69A. Ground No. 1 is accordingly dismissed. 16. In Ground No. 2, the appellant contended that since the AO has neither rejected

Devraj Vishwasrao Jadhav, Pune vs. Income Tax Officer, Ward-3, Satara

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

ITA 2213/PUN/2024[2015-16]Status: DisposedITAT Pune23 Sept 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / .Ita No.2213/Pun/2024 धििेंारण वर्ा /Assessment Year: 2015-2016 Devraj Vishwasrao Ito, Ward-3, Satara Jadhav, R. No. 06, S. No. 24, Vs. Dreams Rhythm, Opposite Talathi Office, Bavdhan, Pune-411021 Maharashtra Pan-Aebpj6968F अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Dr. Prayag Jha Department By: Shri Ramnath P Murkunde Date Of Hearing: 23-09-2025 Date Of Pronouncement: 08-09-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 11.09.2024 Which Is Arising Out Of Order Passed U/S 147 Of The Act Dated 14.03.2023. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. The Ld Cit(A) Erred In Not Considering The Arguments & Submissions Made By The Assessee & Dismissing All The Grounds Taken In Appeal. 2. The Ld Cit(A) Erred In Not Appreciating That The Ld Assessing Officer Had Not Served On The Assessee The Statutory Notice Under Section 143(2) Of The It Act & Therefore, The Impugned Order Was Passed Without Jurisdiction.

For Appellant: Dr. Prayag JhaFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 147Section 148Section 148ASection 250Section 68Section 69A

made addition of Rs.36,35,415/- being cost of equity share purchased through his bank account and the amount was not unexplained money liable to tax under section 69A of the IT Act. 5. The Ld CIT(A) erred in not appreciating that the Ld AO F had made addition ... including the addition for unexplained cash credit u/s 68 of the Act at Rs. 80,11,889/- and Rs. 74,44,000/- addition for unexplained money u/s 69A of the Act at Rs. 36,35,415/- and also the addition for denying the short term capital loss

Gani Lathifsahib Shakila Banu, Trichy vs. The Income Tax Officer, Ward-1(2), Trichy

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

ITA 1952/CHNY/2025[2017-2018]Status: DisposedITAT Chennai23 Sept 2025AY 2017-2018

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. No.1952/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Gani Lathifsahib Shakila Banu, Vs. The Income Tax Officer, 12, A1, First Main Road, Ward 1(2), Ramalinga Nagar, Woriur S.O., Tiruchirappalli. Tiruchirappalli 620 003. [Pan:Bffps0785F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Aarif, Cma Advocate & Ms. Keerthana, Advocate ""थ" की ओर से/Respondent By : Ms. Sandhya Rani Kure, Jcit सुनवाई की तारीख/ Date Of Hearing : 17.09.2025 घोषणा की तारीख /Date Of Pronouncement : 23.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.01.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 465 Days. The Assessee Filed Petition For Condonation Of Delay In Support Of An Affidavit

For Appellant: Shri Aarif, CMA Advocate &For Respondent: Ms. Sandhya Rani Kure, JCIT
Section 69A

Kure, JCIT did report any objection. 6. On perusal of the assessment order, we note that the Assessing Officer made addition on account of unexplained money under section 69A of the Act for want of evidence, which is admitted by the ld. AR. The ld. AR referred to page

DCIT-2(1)(1), Mumbai vs. Kolar Paper Mills Ltd, Mumbai

In the result, revenue’s appeal is dismissed

ITA 1978/MUM/2025[2020-21]Status: DisposedITAT Mumbai23 Sept 2025AY 2020-21

Bench: Shri Pawan Singh & Smt. Renu Jauhriआयकर अपील सुं./Ita No.1978/Mum/2025 (धििाारण वर्ा / Assessment Year: 2020-2021) Dy. Commissioner Of V/S. M/S. Kolar Paper Mills Income Tax, Circle बिाम Ltd. 2(1)(1), Mumbai A 404, Twin Tower Chs Ltd, Room No. 575, 5Th Floor, Lokhandwala, 2Nd Cross Lane, Aayakar Bhavan, M.K. Near, Apna Ghar Andheri Road, Mumbai 400020 West, Mumbai 400053 स्थायी लेखा सुं./जीआइआर सुं./Pan/Gir No: Aadck8381N Appellant/अपीलाथी .. Respondent/प्रधिवादी धििााररिी की ओर से /Assessee By: Shri Ashok Majetia, Ca Shri Ritesh Misra, Cit Dr राजस्व की ओर से /Revenue By: 26.08.2025 स िवाई की िारीख / Date Of Hearing घोर्णा की िारीख/Date Of Pronouncement 23.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax, (Appeals)-48, Mumbai [Cit(A)] Dated 23.12.2024 Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year 2020-2021. 2. The Revenue Has Raised The Following Grounds In This Appeal.

For Appellant: Shri Ashok Majetia, CAFor Respondent: 26.08.2025
Section 132Section 132(4)Section 143(3)Section 153CSection 250Section 69ASection 69CSection 80G

order of Ld. AO and argued that since the assessee had given bogus donation, therefore, the AO was justified in treating the same as unexplained money u/s. 69A r.w.s. 115BBE of the Act. On the other hand, Ld. AR has argued that the sum of Rs. 49 lacs was disallowed ... present case, undisputedly, the appellant has paid donation of Rs. 49,00,000/- from its bank account. Therefore, there is no question of any unexplained money. Accordingly, the addition u/s, 69A of the Act is also unwarranted on the said basis. Further. The AO did not bring out on record