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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

Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1154/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1153/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Sept 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1152/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1151/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Sept 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1150/DEL/2025[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1149/DEL/2025[2012-13]Status: DisposedITAT Delhi17 Sept 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1148/DEL/2025[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1147/DEL/2025[2010-11]Status: DisposedITAT Delhi17 Sept 2025AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1146/DEL/2025[2009-10]Status: DisposedITAT Delhi17 Sept 2025AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Puneet Kulthia, Delhi vs. DCIT, Central Circle-14, Delhi

In the result, appeal of the assessee is allowed

ITA 1145/DEL/2025[2008-09]Status: DisposedITAT Delhi17 Sept 2025AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Suman Malik, CIT DR
Section 143(2)Section 153Section 153ASection 153DSection 154

circumstances of the case and in law, the addition of Rs.3,05,44,960/- made by the assessing officer on account of alleged unexplained money received as commission is beyond the scope of provisions of section 153A of the Act and, therefore, the addition made by the AO is liable ... erred in confirming the addition made by the assessing officer of Rs.3,05,44,960/- on account of alleged unexplained money received as commission and, therefore, the addition made by the AO is liable to be deleted 8. On the facts and circumstances of the case

Dy. CIT, CC-4, Delhi, Jhandewalan vs. Kalamkari Designs Private Limited, Delhi

ITA 341/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Sept 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

Indu Bansal, Karnal vs. DCIT, Central Circle, Karnal

In the result, the addition of Rs

ITA 2863/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh[Assessment Year: 2017-18] Smt. Indu Bansal, Dcit, House No. L-506, Model Central Circle, Town, Karnal, Haryana- Vs Karnal. 132001. Pan- Ahopb3289R Assessee Revenue Assessee By Shri Ved Jain, Adv. & Shri Aman Garg, Ca Revenue By Shri Shravan Kumar Cit(Dr)

Section 132(4)Section 142(1)Section 143(3)Section 153CSection 69

fact that the assessee herself deposited cash in bank accounts of Smt. Shalini Bansal and Sh. Ram Niwas Bansal for routing her unexplained money, through them cannot be avoided. 3.2 The Ld. CIT(A) also noted that the apparent transfer of amount does not look real in this case since ... fact that the assessee herself deposited cash in bank accounts to Smt. Shalini Bansal and Shri Ram Niwas Bansal for routing her unexplained money through them cannot be avoided, is not acceptable in view of absence of any inquiry or any credible evidence suggesting such a finding. To that extent

Reliance Ritu Kumar Pvt. Ltd., (Earlierknown As Ritika Pvt.Ltd., )R, New Delhi vs. ACIT, Central Circle-4, Delhi

ITA 231/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Sept 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

Reliance Ritu Kumar Pvt. Ltd. (Earlier Known As Ritika Private Limited), Tilak Marg vs. ACIT, Central Circle-4, Delhi, Central Circle

ITA 3053/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

DCIT, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2944/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

Deputy Commissioner of Income Tax, Central Circle-04, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2748/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

Deputy Commissioner of Income Tax, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2696/DEL/2023[2014-15]Status: DisposedITAT Delhi17 Sept 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

Dy. Commissioner of Income Tax Central Circle-04, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2279/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Sept 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

ITA No.2696/Del/2023 & Others IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “C” BENCH: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER

Vikash Kumar Tapadia, Jamshedpur vs. Income Tax Officer, Jamshedpur

Appeal of the assessee is allowed for statistical purposes

ITA 235/RAN/2024[2018-19]Status: DisposedITAT Ranchi16 Sept 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.235/Ran/2024 Assessment Year: 2018-19 Vikash Kumar Tapadia….........................…...........................……….……Appellant Tapadia Compound, Chowk Bazar, Jugsalai (Jharkhand)-831006.. [Pan: Acnpt2711L] Vs. Ito, Jamshedpur……………………………….……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 10, 2025 Date Of Pronouncing The Order : September 16, 2025 Order Per Sonjoy Sarma: This Appeal Arises From Order Dated 03.02.2024, Passed U/S 250 Of The Income Tax Act, 1961 (Hereafter "The Act") By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) [Hereinafter "The Ld. Cit(A)]. 2. Brief Facts Of The Case Are That In The Case Of The Assessee For The Assessment Year 2018-19, The Assessing Officer Noticed That The Assessee Was Involved In Certain Financial Transaction. However, Assessee Has Not Disclosed The Same In The Return Of Income For The Relevant Year. In View Of The Above Fact After Giving Opportunity As Per Section 148A & Obtaining Approval From The Competent Authority Or U/S 148A(D) Of The Act Was Passed On 30.03.2022. Accordingly, Notice U/S 148 Of The Act Requesting The Assessee To File Return Of Income. However, In Compliance To The Notice, The Assessee Did Not Respond & The Ao View That Unexplained Loan U/S 68 Of The Act Of Rs. 9,00,000/- Unexplained Money U/S 69C Of The Act, Rs. 60,44,241/- & Capital Gains Of Rs. 30,54,000/-

Section 148Section 148ASection 250Section 68Section 69C

notice, the assessee did not respond and the AO view that unexplained loan u/s 68 of the Act of Rs. 9,00,000/- unexplained money u/s 69C of the Act, Rs. 60,44,241/- and capital gains of Rs. 30,54,000/- I.T.A. No.235/Ran/2024 Vikash Kumar Tapadia was not disclosed

Ralom Borang, Busihi Yada Motors, A Sector vs. Assistant Commissioner of Incomea Tax, Aaykar Bhawan Gs Road

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

ITA 7/GTY/2025[2019-20]Status: DisposedITAT Guwahati16 Sept 2025AY 2019-20

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 10Section 10(26)Section 144Section 147Section 148Section 194JSection 250Section 26Section 69A

cash deposits, the same was also added to the total income of the assessee by the Ld. AO u/s 69A of the Act as unexplained money. With certain other additions, the Ld. AO assessed the total income of the assessee at ₹2,07,16,438/- u/s 147 r.w.s