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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

Mallikarjuna Rao Brahmarauthu, Sanga Reddy vs. ITO., Ward-1, Sanga Reddy

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

ITA 705/HYD/2025[2017-18]Status: DisposedITAT Hyderabad10 Sept 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.705/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Mallikarjuna Rao Income Tax Officer, Vs. Ward-1, Sanga Reddy. Brahmarauthu, Sanga Reddy. Pan:Avppb2671L (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: None. रधजस् व द्वधरध/Revenue By: Ms. Aditi Goyal, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 03/09/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Mallikarjuna Rao Brahmarauthu (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 30.11.2023 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: NoneFor Respondent: Ms. Aditi Goyal, SR-DR
Section 133(6)Section 139(1)Section 142(1)Section 144Section 69A

return of income nor furnished any documentary evidence to explain the deposits, the Ld. AO treated the entire deposits of Rs.35,05,008/- as unexplained money under section 69A of the Act. Accordingly, The Ld. AO completed the assessment under section 144 of the Act ITA No.705/Hyd/2025 4 vide order

Vijayanand Nithyanand, Chittoor vs. Income Tax Officer, Ward-2, Chittoor

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

ITA 488/HYD/2025[2017-18]Status: DisposedITAT Hyderabad10 Sept 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.488/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Vijayanand Income Tax Officer, Vs. Ward-2, Chittoor. Nithyananad, Chittoor. Pan:Aedpn7704H (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri L. Damodara, Advocate. रधजस् व द्वधरध/Revenue By: Ms. Aditi Goyal, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 03/09/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Vijayanand Nithyanand (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Addl/Jcit (A)-2, Gurugram, (“Ld. First Appellate Authority”), Dated 28.01.2025 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri L. Damodara, AdvocateFor Respondent: Ms. Aditi Goyal, SR-DR
Section 143(2)Section 143(3)Section 69A

deposits. However, the assessee could not produce the cash book before the Ld. AO. The Ld. AO therefore treated the deposits as unexplained money under section 69A of the Act and completed the assessment under section 143(3) of the Act vide order dated 19.12.2019, making addition of Rs.7

Sudhakar Akutota, Warangal vs. Income Tax Officer, Ward-1, Warangal

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

ITA 1068/HYD/2025[2013-14]Status: DisposedITAT Hyderabad10 Sept 2025AY 2013-14

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1068/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2013-14) Shri Sudhakar Akutota, Income Tax Officer, Vs. Ward-1, Warangal. Warangal. Pan: Abapa0044M (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri A. V. Raghuram, Advocate. रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 04/09/2025 घोर्णध की तधरीख/Pronouncement: 10/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Sudhakar Akutota (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 05.06.2024 For The A.Y. 2013-14. 2. At The Outset, It Is Noted That There Is A Delay Of 296 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Accompanied By An Affidavit Explaining The Reasons For The Delay. The Learned Authorised

For Appellant: Shri A. V. Raghuram, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR

Rs.1,65,68,373/- in the bank accounts of the assessee, which remained unexplained. The Ld. AO accordingly treated the said amount as unexplained money under section 69A of the Act. Further, the Ld. AO also noted that the assessee was in receipt of rental income of Rs.2 ... Rs.5,010/- during the ITA No.1068/Hyd/2025 6 year under consideration. Since these amounts were also not explained, the same were brought to tax as unexplained money under section 69A of the Act. Accordingly, the Ld. AO completed the assessment under section 147 read with section 144 and section 144B