“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

Devang Rajnikant Shah, Ahmedabad vs. Income Tax Officer, Ward 5(3)(1), Ahmedabad

In the result, the appeal is allowed for statistical purposes

ITA 1090/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad12 Sept 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Virang Mehta, ARFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 147Section 250Section 271ASection 69Section 69A

section 69, of the Act and the alleged scrips/valuables amounting to ₹56,76,902/-, not recorded in the books of accounts, were treated as unexplained money under section 69A of the Act. The Assessing Officer made a total addition of ₹78,20,272/- to the returned income. The AO also

Nandigram Krashi Awam Gram Vikas Sanstha Suga, Nanded vs. DCIT, Exemption Circle, Aurangabad

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

ITA 1762/PUN/2024[2018-19]Status: DisposedITAT Pune12 Sept 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B Phadke (Virtual)For Respondent: Shri Ramnath P Murkunde

Section 133(6)Section 144BSection 147Section 148Section 148ASection 69A

erred in law and on facts in confirming the addition of Rs.3,19,29,681/- u/s 68 of the ITA, 1961 on account of unexplained money made by the learned AO. 2. Learned CIT(A) ought to have granted an appropriate opportunity of being heard to the appellant for making

ITO., Ward-6(1), Hyderabad vs. Swathi Communications, Hyderabad

ITA 961/HYD/2025[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Us:

Section 133(6)Section 147Section 148Section 148A

deposits aggregating to Rs. 31.87 crores (approx.) in its bank accounts, therefore, he held the entire amount as having been sourced out of the unexplained money of the assessee firm under Section 69A of the Act. Accordingly, the J.A.O. vide his order passed under Section 147 r.w.s. 144B

Mohammed Gouse Moinuddin, Hyderabad vs. Income Tax Officer, Ward-14(1), Hyderabad

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

ITA 900/HYD/2025[2014-15]Status: DisposedITAT Hyderabad12 Sept 2025AY 2014-15

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri R. Mohan KumarFor Respondent: Sri Madan Mohan Meena,Sr. AR

Section 139Section 147Section 148Section 69A

explanation along with relevant documentary evidences, the Assessing Officer made addition of Rs.15,78,00,000/- u/sec.69A of the Income Tax Act, 1961 as unexplained money and also made addition on account of interest income of Rs.1,04,388/- and determined the total income of the assessee at Rs.15 ... Kumar, Advocate-Learned Counsel for the Assessee submitted that, the Assessing Officer made addition of Rs.15.78 crore under section 69A of the Act as unexplained money towards credits in bank account, even though, the total credits in the bank accounts of the assessee maintained with Union Bank of India, HDFC

Himabindu, Bangalore vs. ITO., Ward-1, Chittoor

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

ITA 799/HYD/2025[2017-18]Status: DisposedITAT Hyderabad12 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR

Section 143(2)Section 144Section 69Section 69A

without furnishing any explanation, including cash book, cash balance as on 08.11.2016, or source details. Accordingly, he treated the same as unexplained money under section 69A of the Act. He also noted that, the Aircel Ltd. had paid Rs.25,14,149/- to the assessee as commission. Since no reconciliation

Arcot Afsar Begum, Tadipatri vs. Income Tax Officer, Ward-1, Anantapur

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

ITA 1134/HYD/2025[2013-14]Status: DisposedITAT Hyderabad12 Sept 2025AY 2013-14

Bench: The Tribunal Within The Prescribed Period. It Was Contended That The Delay Is Neither Willful Nor Deliberate But Has Occurred On Account Of Genuine & Bona Fide Reasons. Accordingly, He Prayed For Condonation Of The Delay In The Interest Of Substantial Justice. 3. Per Contra, The Learned Departmental Representative (“Ld. Dr") Did Not Raise Any Serious Objection To The Prayer Of The Assessee. 4. We Have Carefully Considered The Submissions Of Both Sides & Perused The Condonation Petition Along With The Affidavit Placed On Record. On Perusal Of The Same, We Are Satisfied That The Assessee Has Shown A Reasonable & Bona Fide Cause For The Delay In Filing The Appeal. It Is Well Settled That When Substantial Justice & Technical Considerations Are Pitted Against Each Other, The Cause Of Substantial Justice Deserves To Be Preferred. In View Of The Above Facts & Circumstances & There Being No Serious Objection From The Revenue, We Condone The Delay Of 95 Days In Filing Of The Appeal. Accordingly, The Appeal Is Admitted For Adjudication On Merits. 5. The Assessee Has Raised The Following Grounds Of Appeal :

Section 115BSection 147Section 44ASection 69A

assessee has raised the following grounds of appeal : ITA No.1134/Hyd/2025 | 3 1. Erroneous Invocation of Section 69A No Basis for Treating Cash Deposits as Unexplained Money: The learned Assessing Officer has erred both in law and on facts in invoking the provisions of Section 69A of the Income ... treat the cash deposits of Rs.29,92,000 in the appellant's bank account as unexplained money. Section 69A contemplates addition only where money is found in the ownership of the assessee but is not recorded in the books of account, and where the assessee fails to offer a satisfactory

Income Tax Officer, Ward 3(1), Hyderabad vs. Stypack Private Limited, Hyderabad

In the result, the appeal of the revenue is dismissed, while the cross-objection of the assessee company is allowed in terms of our aforesaid observations

ITA 997/HYD/2024[2018-19]Status: DisposedITAT Hyderabad12 Sept 2025AY 2018-19

Bench: Us:

Section 132Section 147Section 148Section 148ASection 68

officer u/s 68 of the Act by disallowing the exemption claimed in respect of long terms capital gains and by considering the same as unexplained money. (iii) The learned Commissioner of Income Tax (Appeals) ought to have held that the notice issued u/s 148 of the Act is invalid even

Chaktentul Skus Ltd., Durgapur vs. ITO, Ward 1(1), Durgapur

ITA 1464/KOL/2025[2018-2019]Status: DisposedITAT Kolkata12 Sept 2025AY 2018-2019

Bench: 28-02-2024 & In The Process There Is Delay Of 403 Days In Filing The Instant Appeal. The Main Reason Is The Appellant Was Suffering From Prolonged Illness & Was Under Medical Supervision. The Appellant Is Attaching A Copy Of Medical Certificate Issued By The Doctor In This Respect. 2. That The Limitation Period Prescribed In Income Tax Act, 1961 For Filing The Appeal Before This Appellate Tribunal Against The Order Of The Income Tax Officer Is 60 Days From The Date Of The Receipt Of The Impugned Order.

Section 250Section 270ASection 271ASection 272A(1)(d)Section 69A

upholding the action of the Assessing Officer by added of Rs 47,65,290.00/- u/s section 69A of The Income Tax Act, 1961 as unexplained money although the assessee is not a Co-operative bank, but a Primary Agricultural Co-operative Society. 2. That on the facts ... action of the Assessing Officer by added Rs.47,65,290.00/- u/s 69A of The Income Tax Act, 1961 as unexplained and treated as unexplained money. 3. That on the facts and in the circumstances of the case the learned Commissioner of Income tax (Appeals), National Faceless Appeal Centre, Delhi

Nafees Ahmad, Gonda vs. ITO Ward-52(1), Delhi

In the result, appeal of the assessee is allowed

ITA 4046/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Sept 2025AY 2017-18

Bench: Shri Mahavir Singhasstt. Year : 2017-18 Nafees Ahmad, Vs. Ito-52(1), New Delhi/ Nfac, 115/21, Rakabganj, Kotwali Nagar, Delhi Gonda, Uttar Pradesh-271001 (Pan: Aiopa0771A) (Appellant) (Respondent) Appellant By : Sh. Prashant Kumar Verma, Adv. Respondent By : Sh. Manoj Kumar, Sr. Dr. Date Of Hearing 03.09.2025 Date Of Pronouncement 12.09.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi Dated 18.11.2024 Pertaining To Assessment Year 2017-18. The Solitary Issue Argued By The Ld. Ar Is Relating To Challenging The Notice U/S. 148 Of The Act Dated 27.3.2021 Issued By The Ito, Ward- 52(1), Delhi Is Without Jurisdiction & Is Void Ab Initio & Consequently The Reassessment Is Also Void Ab Initio. 2. Heard Both The Sides & Perused The Records. 3. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Original Return Of Income For The Ay 2017-18 Declaring Total Income Of Rs. 2,60,450/-. Thereafter, The Assessee Filed Revised Return Of Income Declaring Taxable Income Of Rs. 3,12,480/-. As Per The Financial Transactions Reported In The Its, Assessee Has Deposited Cash Amounting To Rs. 18,29,000/- With Indian Overseas Bank At Gonda

For Appellant: Sh. Prashant Kumar Verma, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 115BSection 142(1)Section 147Section 148Section 69A

completed the assessment u/s. 147 r.w.s. 144 r.w.s. 144B dated 30.3.2022 by treating the total cash deposits of RS. 18,29,000/- as unexplained money and brought to tax u/s. 69A of the Act which will be taxed u/s. 115BBE at special rates. Aggrieved with the action

Delhi vs. Sma Goyal Jewellers Pvt Ltd, Delhi

In the result, appeal filed by the assessee is allowed

ITA 5583/DEL/2024[2017-18]Status: DisposedITAT Delhi12 Sept 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Sma Goyal Jewellers Pvt. Ltd., Central Circle-29, I-45, Arya Samaj Road, New Delhi. Vs. Uttam Nagar, West Delhi-110059. Pan:Aajcs4890G (Appellant) (Respondent) Assessee By Shri Sanjeev Batra, Adv. & Shri Kailash Khemani, Ca Department By Shri Narpat Singh, Sr. Dr Date Of Hearing 24.06.2025 Date Of Pronouncement 12.09.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals)-30 In Appeal No. 08/10437/2019-20 Dated 25.09.2024 For Assessment Year 2017-18 Arising Out Of Assessment Order Passed U/S 143(3) Of The Income Tax Act, 1961 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Company & E-Filed Its Return Of Income On 23.10.2017 Declaring Total Income At Rs.4,35,580/-. The Case Of The Assessee Was Selected For Complete Scrutiny. Assessee Has Made Cash Deposit Of Rs.98,00,000/- In Specified Bank Notes (Sbn) In Kotak Mahindra Bank Account. During The Course Of The Assessment Proceedings, Details Have Been Asked For Time To Time & The Assessing Officer Has Issued Summons To The Parties To Whom Sales Stated To Have Been Made In Cash. Since, Most Of The Parties Has Not Responded To The Notices Issued By The Assessing Officer, He Was Of The Opinion That Cash Deposited During

Section 133(6)Section 143(3)Section 68Section 69A

Assessing Officer, he was of the opinion that cash deposited during 2 IT No.5583/Del/2024 ACIT vs. SMA Goyal Jewellers Pvt. Ltd. demonetization is unexplained money of assessee and made the additions of Rs.78,00,000/- u/s 69A r.w.s 115BBE of the Act. 3. Against this order, assessee preferred an appeal ... sample verification notices under section 133(6), and other circumstantial deficiencies, the AO treated Rs. 78,00,000/- as unexplained money under section 69A of the Act and taxed it under section 115BBE. CIT(A) order:- The assessee preferred an appeal challenging the reassessment order passed under section

ITO Ward 24(1), New Delhi vs. Sourabh Logistics Pvt. Ltd., New Delhi

Appeal of the Revenue is partly allowed

ITA 1060/DEL/2023[2013-14]Status: DisposedITAT Delhi12 Sept 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 133(6)Section 143(3)Section 250Section 68

redeposit in the bank accounts. It is thus submitted by ld. AR that there is no reason to hold these cash deposits as unexplained money of the assessee. Ld. AR submits that Id. CIT(A) appreciated Page | 15 ITA No.1060/Del/2023 these facts and deleted the additions. He thus, prayed

Sh. Vinod Kumar Jain, Kota vs. ACIT, Central Circle, Kota

In the result both these appeals of the assessee are allowed

ITA 647/JPR/2025[2019-20]Status: DisposedITAT Jaipur11 Sept 2025AY 2019-20

Bench: Dr. Mitha Lal Meena, Hon’Ble & Dr. S. Seethalakshmi, Hon’Ble

Section 115BSection 132(4)Section 68Section 69B

upholding the finding of AO that excess cash of Rs.3,73,417/- found in search offered for tax in the return of income is unexplained money u/s 69B of the Act taxable u/s 115BBE of the Act by not accepting the explanation of assessee that source of such cash ... from the business operations carried out by him duly incorporated in the books of accounts and therefore it is not unexplained money u/s 69B of the Act so as to attract section 115BBE of the Act. Grounds of Appeal ITA NO. 646/JPR/2025: 3. Facts as per record are that

Sh. Vinod Kumar Jain, Kota vs. ACIT, Central Circle, Kota

In the result both these appeals of the assessee are allowed

ITA 646/JPR/2025[2018-19]Status: DisposedITAT Jaipur11 Sept 2025AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon’Ble & Dr. S. Seethalakshmi, Hon’Ble

Section 115BSection 132(4)Section 68Section 69B

Dungar Singh Meena, Jaipur vs. ITO Ward 7(2), Jaipur

In the result, these appeals filed by the assessee are allowed for statistical

ITA 563/JPR/2025[2018-19]Status: DisposedITAT Jaipur11 Sept 2025AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon’Ble & Dr. S. Seethalakshmi, Hon’Ble

Section 148Section 270ASection 271Section 69A

facts of the case in .making whopping addition of Rs.4,80,35,820/- by considering cash deposit into bank account (Current Account) to be Unexplained Money u/s 69A without appreciating that same emanated out of sale proceeds of business and only Income component ought to have brought to taxation