“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

Chetan Agarwal, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1052/HYD/2025[2020-21]Status: DisposedITAT Hyderabad10 Sept 2025AY 2020-21

Bench: Us:

Section 115BSection 143(3)Section 144Section 234ASection 234BSection 234CSection 250Section 69Section 698Section 69A

erred in upholding the act of the learned AO who determined the entire amount of seized cash of Rs. 2,11,82,000/- as unexplained money u/s. 69A of the Act and therefore, as income of the assessee for the AY 2020-21 7. On the facts and circumstances

Milan Mallick, Bagda vs. ITO, Ward 50(1), Kolkata

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

ITA 1170/KOL/2025[2017-2018]Status: DisposedITAT Kolkata10 Sept 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144Section 250Section 69A

respect of fund deposited in Bank Accounts which has not commensurate with return of income as well as added back to income as unexplained money u/s 69A and taxed to income u/s 115BBE of the Income tax Act, 1961 although the Adjudicating Authority failed to collect evidence from investigating part

Samiruddin Khan, Burdwan vs. ITO, Ward 1(2), Burdwan

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

ITA 1169/KOL/2025[2017-2018]Status: DisposedITAT Kolkata10 Sept 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143Section 143(3)Section 250

served upon the assessee but the assessee did not comply to the same. The Assessing Officer (hereinafter referred to as Ld. 'AO') added the unexplained money credited in the undisclosed bank account to the tune of ₹14,853/-, unexplained money deposited in SBNs during the demonetization period to the tune

Thambu Sami, Rep. by L/H Mr. Senthil Kumar, Cuddalore vs. ITO, Ward-2., Cuddalore

In the result, the appeal filed by the assessee is allowed for statistical purpose whereas the Cross objection of the revenue is become infructuous

ITA 986/CHNY/2025[2011-12]Status: DisposedITAT Chennai10 Sept 2025AY 2011-12

Bench: Hon'Ble Shri Manu Kumar Giri & Shri Hon'Ble Amitabh Shukla**

For Appellant: Shri S. Sridhar, Advocate. **12

Section 143(3)Section 148Section 69A

total income of Rs.2,00,59,403/- after making an addition of Rs.2,00,00,000/- on account of cash deposit as unexplained money u/s.69A of the Act. Assessee further challenged the order of assessment passed u/s.143(3) r.w.s. 147 of the Act before the ld. CIT(A) who dismissed

Deputy Commissioner of Income Tax, Delhi vs. Artex Textile Private Limited, Delhi

Appeal is dismissed

ITA 5005/DEL/2024[2017-18]Status: DisposedITAT Delhi10 Sept 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Dr. Kapil Goel, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142Section 142(1)Section 143(2)Section 144

bank accounts during the demonetization period and it is upon the assessee to furnish an explanation about the nature and source of unexplained money, or other valuable article owned by the assessee to the satisfaction of the Assessing Officer. He further observed that in respect of the deposits, no proper ... provisions of section 68 of the T Act, it is upon the assessee to furnish an explanation about the nature and source of unexplained money, or other valuable article owned by the assessee to the satisfaction of the Assessing Officer?" 10. At the time of hearing, Ld DR submitted that

Laxmi Narcinva Urban Co-Operative Credit Society Limited, Margao vs. Income Tax Officer, Ward - 3, Margao

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

ITA 185/PAN/2025[2017-18/]Status: DisposedITAT Panaji09 Sept 2025

Bench: Shri Pavan Kumar Gadalei T A. Nos.185/Pan/2025 (A.Y. 2017-18 ) Laxmi Narcinva Urban Vs Ito-Ward-3, Cooperative Credit Society Ltd, Blessings Pioneer . Katkar Guru Ashish Building, Complex, 1 St Floor,Rua Clovis Costa Old Market, Road, Margoa-403601, Margoa-403601, Goa. Goa. Pan .No. Aaajl1003E (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri. Pramod.Y.Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 08.09.2025 घोषणा की तारीख/Date Of Pronouncement 09.09.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay Of In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Application & Affidavit For Condonation Of Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections.

Section 68

compliance. Whereas the A.O. has dealt on the provisions of section 68 of the Act and made addition of unexplained cash credits/ unexplained money and assessed the total income of Rs.36,92,400/- and passed the order u/sec 143(3) of the Act dated 28.12.2019. 4. Aggrieved by the order

Ponipireddy Rajyalakshmi, Eluru vs. Income Tax Officer, Ward-1, Eluru

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

ITA 362/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2019-20

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

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

29/03/2024 U/s. 147 r.w.s 144 of the Act by making an addition of Rs. 47,15,106/- U/s. 69A of the Act towards unexplained money. Thus, the Ld. AO passed the assessment order dated 29/03/2024 and determined the total income of the assessee

Narasimha Rao Jammigumpula, Guntur vs. Income Tax Officer, Narasaraopet

In the result, appeal of the assessee is allowed

ITA 331/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2015-16

Bench: the Ld. CIT(A).

Section 142(1)Section 147Section 148Section 148ASection 149(1)Section 151ASection 69A

assessment ex-parte on the basis of the record. Thus, the Ld. AO treated the total cash deposits of Rs. 48,19,517/- as unexplained money U/s. 69A of the Act and completed the assessment and determined the assessed income at Rs. 48,19,517/- and passed the assessment order ... able to establish the nature and source of these cash deposits and hence the same have correctly been brought to tax U/s. 69A as unexplained money in the hands of the assessee. Thus, the addition of Rs. 48,19,517/- was confirmed by the Ld. CIT(A). Aggrieved

Moturu Chandra Sekhara Rao, Usa vs. The Income Tax Officer, Ward 2(1), Vijayawada

In the result, appeal of the assessee is allowed for statistical purposes as indicated herein above

ITA 474/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam09 Sept 2025AY 2015-16

Bench: The Tribunal. In Respect Of The Belated Filing Of The Appeal, The Assessee Filed A Petition For Condonation Of Delay Along With An Affidavit & The Relevant Contents Are Scanned & Pasted Herein Below:

Section 147Section 249(4)

offer the same for taxation by filing the return of income. Thus, the Ld. AO made addition of Rs. 61,35,000/- as unexplained money and Rs. 62,471/- as income from other sources thereby determining the total income of the assessee at Rs. 61,97,471/-. Aggrieved

Pradeep Sharma, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 1522/JPR/2024[2017-18]Status: DisposedITAT Jaipur09 Sept 2025AY 2017-18

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR

Section 143(3)Section 36(1)(vii)

claim that it relates to business. Therefore, the amount is liable to be added under deeming provision of 69A. Section 69A reads as under. Unexplained money, etc. 69A. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article ... invocation provision of section 69A of the Act it would be desirable to go through the provision of that section which reads as follows; Unexplained money, etc. 69A. Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article

Shri Jayshivrai Nagri Sahakari Patsanstha Limited, Kolhapur vs. ITO, Ward-1, Kolhapur

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

ITA 1257/PUN/2025[2018-19]Status: DisposedITAT Pune09 Sept 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1257/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Shri Jayshivrai Nagri Sahakari V The Income Tax Officer, Pathsanstha Limited, S Ward-1, Kolhapur. 2832B Ward Yamula Devalaya Najik Karveer, Kolhapur – 416012. Maharashtra. Pan: Aaqas6598A Appellant/ Assessee Respondent / Revenue Assessee By None. Revenue By Shri Aviyogi Ambadkar– Addl.Cit(Dr) Date Of Hearing 08/09/2025 Date Of Pronouncement 09/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 13.11.2024 For The A.Y.2018-19 Emanating From The Assessment Order Under Section 147 R.W.S 144 Of The Income Tax Act, 1961, Dated

Section 147Section 250Section 250(4)Section 270ASection 271ASection 272A(1)(d)Section 69A

facts and in the circumstances of the case, the CIT(A) erred in making additions of Rs.80,33,693/- on account of unexplained money under section 69A of the Act when the assessee fully explained the cash deposits and credits in the bank account 2 On the facts ... facts and in the circumstances of the case, the AO erred in making additions of Rs. 80,33,693/- on account of unexplained money under section 69A of the Act when the assessee fully explained the cash deposits and credits in the bank account 2. On the facts

Vineet Bajoria, Kolkata vs. ITO, Ward 45(4), Kolkata

In the result, both the appeals are allowed

ITA 231/KOL/2025[2013-2014]Status: DisposedITAT Kolkata09 Sept 2025AY 2013-2014

Bench: S/Shri & Rajesh Kumar & Pradip Kumar Choubeyita Nos.228, 229, 230 & 231/Kol/2025 Assessment Year : 2013-14 Vineet Bajoria, C/O. S.N.Ghosh Vs. Ito, Ward 45(4), Kolkata & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata Pan/Gir No. Adupb 1299 F (Appellant) .. ( Respondent) Assessee By : Shri Somnath Ghosh, Adv Revenue By : Shri S.B.Chakraborthy, Sr Dr

For Appellant: Shri Somnath Ghosh, AdvFor Respondent: Shri S.B.Chakraborthy, Sr DR

Section 24Section 80CSection 80DSection 80T

issue raised in Ground No.4 is against the confirmation of addition of Rs.6,57,501/- as made by the Assessing Officer on account of unexplained money. 4. Facts in brief are that the Assessing Officer during the course of assessment proceedings observed from the bank statement of State Bank

Vineet Bajoria, Kolkata vs. ITO, Ward 45(4), Kolkata

In the result, both the appeals are allowed

ITA 230/KOL/2025[2013-14]Status: DisposedITAT Kolkata09 Sept 2025AY 2013-14

For Appellant: Shri Somnath Ghosh, AdvFor Respondent: Shri S.B.Chakraborthy, Sr DR

Section 24Section 80CSection 80DSection 80T

Vineet Bajoria, Kolkata vs. ITO, Ward 45(4), Kolkata

In the result, both the appeals are allowed

ITA 229/KOL/2025[2013-2014]Status: DisposedITAT Kolkata09 Sept 2025AY 2013-2014

For Appellant: Shri Somnath Ghosh, AdvFor Respondent: Shri S.B.Chakraborthy, Sr DR

Section 24Section 80CSection 80DSection 80T

Vineet Bajoria, Kolkata vs. ITO, Ward 45(4), Kolkata

In the result, both the appeals are allowed

ITA 228/KOL/2025[2013-2014]Status: DisposedITAT Kolkata09 Sept 2025AY 2013-2014

For Appellant: Shri Somnath Ghosh, AdvFor Respondent: Shri S.B.Chakraborthy, Sr DR

Section 24Section 80CSection 80DSection 80T

Bibhu Prasad Sahoo, Puri vs. Income Tax Officer Ward 62(3), Kolkata

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

ITA 21/KOL/2025[2017-2018]Status: DisposedITAT Kolkata09 Sept 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143Section 143(2)Section 143(3)Section 250Section 69

demonetization period on three different dates. After considering the assessee’s reply, the Ld. AO made the addition of Rs.1,31,465/- as unexplained money u/s 69A by treating it to be the assessee’s deemed income, which has been confirmed by the Ld. CIT(A). It is submitted that

S. Panneerselvam, Chennai vs. ITO, Ncc-10(3), Chennai

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

ITA 1688/CHNY/2025[2018-19]Status: FixedITAT Chennai09 Sept 2025AY 2018-19

Bench: S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.1688/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 S. Panneerselvam, Vs. The Income Tax Officer, No. 11, Vivek Nagar, Kolathur, Non Corporate Circle 10(3), Chennai 600 099. Chennai. [Pan: Ainpp3051B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई की तारीख/ Date Of Hearing : 04.09.2025 घोषणा की तारीख /Date Of Pronouncement : 09.09.2025 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. This Appeal Is Filed With A Delay Of 43 Days. The Assessee Filed Petition For Condonation Of Delay Stating The Reasons In Support Of An Affidavit. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, I Find The Reasons Stated By The Assessee Are Bonafide, Which 2

For Appellant: NoneFor Respondent: Ms. V. Aswathy, JCIT

Section 147Section 148Section 292BSection 69ASection 69C

r.w.s. 144B of the Income Tax Act, 1961 [“Act” in short] dated 29.03.2022 disallowed an amount of ₹.11,80,000/- on account of unexplained money under section 69A of the Act since the assessee did not explain the source of income. Further, the Assessing Officer disallowed

Nithyananda Talanki Krishnamurthy(HUF), Bangalore vs. Income Tax Officer, Ward-2(2)(5), Bangalore

The appeal of the assessee is allowed for statistical purposes

ITA 857/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri G Venkatesh, CAFor Respondent: Shri Ganesh R Ghale, Advocate Standing Counel for Revenue

Section 143(3)Section 271ASection 69

only. In the assessment order completed under section 143(3) of the Act dated 3rd December 2019 the impugned cash deposit was treated as unexplained money under section 69 of the Act and added to the total income of the assessee. . Page 4 of 7 9. The aggrieved assessee preferred

Mr. Ravindranath Shetty, Mangaluru vs. Income Tax Officer, Ward-2(4), Mangaluru

Appeal of the assessee is allowed

ITA 51/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Sept 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2014-15

For Appellant: Shri Sheetal, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)

Section 69A

assessment year 2014-15. 2. The issue raised by the assessee relates to the sources of cash deposit which was treated as unexplained money under section 69A of the Act. The assessee deposited cash of ₹69,60,000 in different bank accounts during the year. The assessee explained that ... income. The Assessing Officer accepted retirement withdrawals only to the extent of ₹33,16,500 and treated the balance of ₹36,43,500 as unexplained money u/s 69A of the Act. The ld. CIT(A) confirmed this addition. 4. Being aggrieved by the order

Incometax Officer, Mumbai vs. Shirish J Bhatt, Mumbai

In the result, both the appeals of the revenue are partly allowed

ITA 2889/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Sept 2025AY 2013-14

Bench: Shri Pawan Singh

Section 132(4)Section 254(1)

assessee is one of the bogus entities out of 347 entities. The assessing officer accordingly made addition of unexplained cash credit as well as unexplained money aggregating of Rs. 5,12,560/-. The ld. CIT(A) restricted the addition to the extent of 1.00% of accommodation entry on debit side