“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

Patna Iron Pvt. Ltd., Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of

ITA 332/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR

Section 132Section 143(2)Section 143(3)Section 153ASection 153C

amount of Rs 3,67,50,000/- recorded in the seized material LT 02 under section 69 of the Act by treating it as unexplained money and alleged that the assessee has done this hawala transaction to settle the unaccounted purchases made by the assessee. In the appellate proceedings

Sushil Kumar Kanodia, Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR

Section 132Section 143(2)Section 143(3)Section 153ASection 153C

Ram Nath Jaiswal, Faizabad vs. Commissioner of Income-Tax (Appeals), Lucknow

In the result, the appeal of the assessee is allowed for statistical purposes while the Stay application is held to be allowed

ITA 13/LKW/2024[2018-19]Status: DisposedITAT Lucknow26 Feb 2026AY 2018-19

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Akash Agrawal, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR

Section 143(3)Section 250Section 69A

facts by confirming the applicability of Section 69A of the Income Tax Act, 1961 by treating the said cash deposit as unexplained money and not recording in books of accounts without appreciating the fact that each and every cash was duly recorded in books of accounts. Further, the Financial Statement ... same was duly furnished before the Assessing Officer and Commissioner of Income Tax Appeals and thus invoking the provisions of Section 69A as unexplained money to the cash deposits made was not warranted and the addition cannot be sustained. 3. That the Ld. Commissioner of Income Tax Appeals has erred

Zala Hardattsinh, Ahmedabad vs. The ITO, Ward-3(2)(2) Present Ward-3(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 2134/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri P.F. Jain, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R

Section 115BSection 133(6)Section 144Section 234ASection 69A

under consideration. Since the assessee has not given any explanation, the Assessing Officer considered the cash deposit amounting to Rs. 22,65,717/- as unexplained money u/s. 69A of the Income Tax Act, 1961 and treated the same as total income of the assessee for assessment year

ITO-WD-1(2)(1), Ahmedabad vs. Avs Corporation, Ahmedabad

In the result, all the three appeals of the Revenue stand dismissed

ITA 1627/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &

Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

justified in deleting the addition made of Rs.7,65,00,000/- u/s 69A r.w.s. 115BBE of the Act. being unexplained money, without appreciating the fact that sufficient evidence was found during search and providing cross examination to assessee is not necessary when other evidences are available?" 2. “Whether ... excel sheet was Rs. 7,65,00,000/-. The Assessing Officer treated the above amounts totalling to Rs. 7,65,00,000/- as unexplained money under section 69A read with section 115BBE of the Act and added back to the returned income. 3.7 Further, based on the report

ITO-WD-1(2)(1), Ahmedabad vs. Avs Corporation, Ahmedabad

In the result, all the three appeals of the Revenue stand dismissed

ITA 1621/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2019-20

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &

Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

ITO-WD-1(2)(1), Ahmedabad vs. Avs Corporation, Ahmedabad

In the result, all the three appeals of the Revenue stand dismissed

ITA 1620/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &

Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

Nistala Sudha, Keonjhar vs. ITO., Ward-9(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 605/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad26 Feb 2026AY 2016-2017

Bench: Shri Manjunatha, G.A N D Shri Ravish Soodआ.अपी.सं /Ita No./605/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Nistala Sudha Vs. Ito Keonjhar, Odhisha Ward 9(1) Pan:Emcps9399C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri D. Parida, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 25/02/2026 घोषणा की तारीख/Pronouncement: 26/02/2026 आदेश/Order Per Manjunatha, G. A.M.

For Appellant: Shri D. Parida, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 147Section 148Section 148ASection 69A

tune of Rs.17,17,597/- has not been explained. Therefore, made addition of Rs.17,17,597/- u/s 69A of the Act, as unexplained money. 7. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee challenged the addition ... assessee with regard to the source for cash deposits of Rs.4,97,000, has finally assessed the balance amount of Rs.17,17,597/- as unexplained money u/s 69A of the Act. From the order passed by the Ld. AO u/s 148A(d) of the Act, dated 22/03/2023 for issuance

Hemalatha Chervu, Hyderabad vs. ITO, Ward - 15(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1966/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1966/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Smt. Hemalatha Chervu Vs. Income Tax Officer Hyderabad Ward 15 (1) Pan:Aodpc8304C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Akash Deshpande, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 25/02/2026 घोषणा की तारीख/Pronouncement: 26/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 06/11/2025, For The A.Y 2015-16. 2. The Brief Facts Of The Case Are That The Assessee, An Individual, Not Filed Her Return Of Income For The A.Y 2015-16. The Page 1 Of 11

For Appellant: Shri Akash Deshpande, CAFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 133(6)Section 142(1)Section 147Section 148Section 149(1)(b)Section 69A

total income of the assessee at Rs.60,21,818/-, by making additions of Rs.60,21,818/- under section 69A of the Act, as unexplained money. 3. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT (A). Before the Ld. CIT (A), the assessee neither appeared

Gobinda Adhikary, Kolkata, West Bengal vs. Ward 34(1), Kolkata, West Bengal

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

ITA 2802/KOL/2025[2017-18]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144Section 147Section 148Section 154Section 250Section 69Section 69A

Officer (AO) under Section 69A of the Income tax Act, 1961, holding the cash deposited during the Specified Bank Notes (SBN) period (demonetization) as unexplained money. Ground No. 2: Wrongful Invocation of Section 115BBE That the Ld. CIT(A) erred, in law and on facts, in confirming the invocation

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

ITA 2750/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

ITA 2749/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

In the result, all the 3 appeals filed by the Assessee are partly

ITA 2748/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

students. However, the cash deposited by the assessee in the bank accounts during the demonetization period amounting to *50,14,820/- was treated as unexplained money and the addition was made by invoking section 69A of the Act. The Assessing Officer (hereinafter referred to as Ld. 'AO') concluded that since ... above for grounds. Since these Grounds of Appeal relate to the addition of Rs. 50,14,820/- made by the Ld. AO as unexplained money under section 69A of the Income Tax Act, 1961, the same are being adjudicated together. The Ld. AO was in possession of information that

Minakshi Das, Jalpaiguri vs. I.T.O., Ward - 1(3), Siliguri

In the result, the appeal of the assessee is allowed

ITA 1648/KOL/2025[2019-2020]Status: DisposedITAT Kolkata26 Feb 2026AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Soumitra Choudhary, DRFor Respondent: Shri Mangtinlen Haokip, DR

Section 147Section 148Section 148ASection 69A

Page | 2 ITA No. 1648/KOL/2025 Minakshi Das; A.Y. 2019-20 account of money deposited in the bank by treating the same as unexplained money u/s 69A of the Act. 4.1. The facts in brief are that the assessee has not filed the return of income for the impugned assessment year

Deputy Commissioner of Income Tax, Cnetral Circle-4(3), Kolkata vs. Dilip Kumar Ghosh, Kolkata

In the result, the appeal of the Revenue and CO of the Assessee are

ITA 1606/KOL/2025[2018-19]Status: DisposedITAT Kolkata26 Feb 2026AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri Madhu Malti Ghosh, DR

Section 115BSection 153ASection 69A

basis of seized documents DKG-01 and DKG-04, by observing that cash payments as contained in those documents were unexplained money u/s 69A of the Act. We note that the similar issue was also involved in the previous assessment year i.e. A.Y. 2017-18 based on the same document ... assessee and added the entire amount pertaining to this year amounting to 71,48,86,218/- u/s 69A of the Act as unexplained money in the assessment framed u/s 153A of the Act dated 31.03.2022. 5. In the appellate proceedings, the Id. CIT (A) allowed the appeal of the assessee

Bangalore Union Services Pvt. Ltd., Chennai vs. DCIT, Corporate Circle-1(2), Chennai

In the result, the appeal of the assessee is allowed

ITA 2483/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT

Section 147Section 2(22)(e)

order of AO as bad in law as it involves improper initiation of reassessment proceedings with consequent additions on account of deemed dividend and unexplained money as involving not acceptable additions as per the facts of case and thereby pleaded to delete the order ... words, authorized capital is Rs.1,00,00,000/- and subscribed capital is Rs.1,54,400/-. This share application money required to be assessed as unexplained money”. 9. The ld. AR submitted that the AO’s initiation of reassessment proceedings regarding the additions of Rs.2,99,25,000/- made

Sonal Kamal Gupta, Mumbai vs. The Dy Commissioner of Incoem Tax Central Circle -5(1), Mumbai

Appeal of the Assessee is allowed for statistical purposes

ITA 2296/MUM/2025[2022-23]Status: DisposedITAT Mumbai26 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Bijayananda Pruseth

Section 250Section 69A

circumstances of the case and law on the subject, the learned assessing officer erred in making addition of Rs. 75,00,000/- as unexplained money u/s 69A r.w.s 115BBE of the Income Tax Act, 1961. The learned CIT(A) erred in upholding the action of the Id.AO by confirming

Kusum Jagdishkumar Gupta, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle 5(1), Mumbai

Appeal of the Assessee is allowed for statistical purposes

ITA 2135/MUM/2025[2022-23]Status: DisposedITAT Mumbai26 Feb 2026AY 2022-23

Bench: Shri Sandeep Gosain & Shri Bijayananda Pruseth

Section 250Section 69A

circumstances of the case and law on the subject, the learned assessing officer erred in making addition of Rs. 1,50,00,000/- as unexplained money u/s 69A r.w.s 115BBE of the Income Tax Act, 1961. The learned CIT(A) erred in upholding the action of the Id.AO by confirming

Hemant Kumar Tikariha, Raipur vs. Income Tax Officer, Ward-1(1), Raipur

In the result, appeal of the assessee in ITA No

ITA 98/RPR/2026[2012-13]Status: DisposedITAT Raipur25 Feb 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.97 & 98/Rpr/2026 "नधा"रण वष" /Assessment Years : 2011-12 & 2012-13

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 69Section 69A

creditworthiness of the donor and the genuineness of the transaction, the alleged gift remains unsubstantiated and is accordingly treated as the appellant's own unexplained money. 5.5 The appellant has further claimed that the cash deposits represent agricultural income and has relied upon a certificate issued by Jila Sahakari Bank

Hemant Kumar Tikariha, Raipur vs. ITO, Ward-1(1), Raipur

In the result, appeal of the assessee in ITA No

ITA 97/RPR/2026[2011-12]Status: DisposedITAT Raipur25 Feb 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.97 & 98/Rpr/2026 "नधा"रण वष" /Assessment Years : 2011-12 & 2012-13

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 69Section 69A