“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

Income Tax Officer, Ward-1(3)(1), Ahmedabad vs. Rajeshkumar Rameshchandra Shah, Ahmedabad

In the result, appeal filed by the Revenue is dismissed

ITA 1074/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2017-18

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Alpesh Parmar, CIT. DRFor Respondent: Shri Tushar Hemani, Sr. Advocate &

Section 250Section 68

then one part of credit side of the trading account, that is, sales cannot be discarded completely so as to hold that it is unexplained money. 18. Our finding given above is peculiar to this case. because here in this case in the earlier years, scrutiny assessment have been done

Khaja Mohmmed Ghousuddin, Hyderabad vs. ITO., Ward-11(1), Hyderabad

In the result, appeal of the Assessee is partly allowed

ITA 387/HYD/2025[2017-18]Status: DisposedITAT Hyderabad04 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Mohammed Faisal PashaFor Respondent: Sri Suresh Babu KN, Sr. AR

Section 115BSection 142(1)Section 250Section 69A

there were no response from the assessee, the Assessing Officer has completed the assessment by treating the cash deposits of Rs.4,90,500/- as unexplained money u/sec.69A read with Section 115BBE of the Income Tax Act, 1961 of I.T. Act, 1961. 3. On being aggrieved, the assessee preferred appeal before

Muralidhar Kamisetty, Hyderabad vs. ITO., Ward-13(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1031/HYD/2025[2017-18]Status: DisposedITAT Hyderabad04 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Sri T. Chaitanya Kumar, AdvocateFor Respondent: Sri Suresh Babu KN, Sr. AR

Section 143(3)Section 250Section 69Section 69A

pensioner and he might have saved some money for medical and health purpose and adding the balance amount of Rs.9,07,000/- as unexplained money in accordance with the provisions of section 69A of the Income Tax Act, 1961. 3. Aggrieved by the assessment order, the assessee preferred learned

K N Dileep, Bangalore vs. Income Tax Officer, Ward-1, Ramnagar

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

ITA 1346/BANG/2025[2017-18]Status: HeardITAT Bangalore04 Sept 2025AY 2017-18

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

For Appellant: Sri Vijay Simha, A.RFor Respondent: Shri Balusamy N., D.R

Section 250Section 253(5)

assessee vehemently submitted that the AO erred in treating the entire cash deposit in bank account aggregating Rs.95,91,810/- as unexplained money u/s 69A of the Act apart from computing presumptive business income and interest income and assessed on a total income of Rs.1,00,62,955/- and thus

Pushpavati Janardhan Rao, Mumbai vs. ITO Ward 26(2)(7), Mumbai

In the result, the AO is directed to delete the addition to the extent of Rs

ITA 4586/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Sept 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2017-18 Pushpavati Janardhan Rao, Income Tax Officer, 1802, Atri Towers, Ward-26(2)(7), Saptarishi Park, Vs. Kautilya Bhavan, Swapnanagari, C-41 To C-43, G Block, Mulund West, Bandra Kurla Complex, Mumbai-400080. Bandra (East), Pan : Aadpr9553L Mumbai-400051 (Appellant) (Respondent) For Assessee : None (Adjourment Application) For Revenue : Shri Virabhadra Mahajan, Sr.Dr Date Of Hearing : 02-09-2025 Date Of Pronouncement : 04-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 30-05-2025, Pertaining To Assessment Year (Ay) 2017-18, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: None (Adjourment Application)For Respondent: Shri Virabhadra Mahajan, Sr.DR

Section 69A

Ld.CIT(Appeals)") has erred in sustaining addition of Rs.30,58,500/- by alleging the SBN deposited in bank account during the demonetization period as unexplained money 2 under section 69A of the Act without appreciating the favourable comments of the Ld. Assessing Officer in the remand report; including the following ... under section 69A of the Act in respect of the SBN deposited in bank account during the demonetization period alleging it to be unexplained money merely because as per the view of the Ld. Assessing Officer (based on notifications issued by Central Government) it was impermissible to transact

Zeba Zubair Khan, Mumbai vs. Income Tax Officer 42(1)4, Mumbai

In the result, the appeal by the assessee is allowed

ITA 4129/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Sept 2025AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Girish Agrawal

For Appellant: Shri Poojan MehtaFor Respondent: Shri Bhagirath Ramawat, Sr.DR

Section 142(1)Section 143(2)Section 250Section 69A

entire sum of INR 11,13,500 deposited by the assessee in cash in her bank account was treated as unexplained money and added to her total income under section 69A of the Act. 7. During the appellate proceedings before the learned CIT(A), the assessee filed evidence and explanation

Ranjana Sanjay Tiwari, Mumbai vs. Income Tax Officer -(3), Palghar

In the result, the appeal by the assessee is allowed

ITA 4239/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Sept 2025AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalranjana Tiwari, Tiwari Compound, Baba Ki Lila Bhawan, Bungalow No.1, Kacheri Road Palghar, Mumbai - 401404 ............... Appellant Pan : Afypt8103L V/S Income Tax Officer – (3), ……………… Respondent Bidco Road Palghar, Mumbai - 401404 Assessee By : Shri Poojan Mehta Revenue By : Shri Bhagirath Ramawat, Sr.Dr

For Appellant: Shri Poojan MehtaFor Respondent: Shri Bhagirath Ramawat, Sr.DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

made the addition of the entire cash of INR 27,70,985 deposited by the assessee during the demonetisation. By treating the same as unexplained money under section 69A of the Act. 7. The learned CIT(A), vide impugned order, granted partial relief to the assessee and restricted the addition

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 186/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 119Section 142(1)Section 147Section 148Section 69A

confirming the action of the Income-tax Officer, Ward 3(1)(1), Rajkot in making addition of Rs. 22,35,842/- by way of unexplained money u/s 69A of the Act. 4. On merits, the learned Commissioner (Appeals), erred in confirming the action of the Income-tax Officer, Ward ... ground that the credit was mere a procurement of money without proper explanation of how and why it has come to the assessee; hence unexplained money. 4. Aggrieved by the order of the AO, the assessee carried the matter in appeal before the ld.CIT(A) who has confirmed the action

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, Ward 3(1)(1), Rajkot-

In the result, the appeal of the assessee is allowed

ITA 185/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 119Section 142(1)Section 147Section 148Section 69A

Evexia Lifecare Limited, Vadodara vs. The ITO, Ward-1(1)(1), Vadodara

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

ITA 605/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Sept 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 147Section 148

confirming the addition of Rs.78,29,220/- made by the National Faceless Assessment Unit (hereinafter referred to as "the AO"), treating the same as unexplained money and considering it as commission income at 5% on credit transactions in the bank account of Equitas Small Finance Bank, having account number

Gangadhar Agarwal, Nizamabad vs. ITO., Ward-1, Nizamabad

ITA 697/HYD/2025[2017-18]Status: DisposedITAT Hyderabad03 Sept 2025AY 2017-18

Section 142(1)Section 143(3)Section 44A

closing stock is appearing in the financial statements: Deemed to be unexplained expenditure u/s.69C 1930 quintals is missing as closing stock or sales : Unexplained Money u/s.69A Neither the sales nor the closing stock is appearing in the financial statements: Deemed to be unexplained expenditure u/s.69C The closing stock ... closing stock shown as 26420 quintals shown in trading account. Hence the difference of 5270 Quintals is missing as closing stock or sales: Unexplained Money u/s.69A Actual closing stock was shown in Trading account as 1020 quintals against 820 as per purchase and sales, thereby there is hidden purchases

Navodaya Mutually Aided Co-Operative Thrift Society Limited, Udamgadda vs. ITO., Ward-8(2), Hyderabad

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

ITA 334/HYD/2025[AY 2017-18]Status: DisposedITAT Hyderabad03 Sept 2025

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.334/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) M/S. Navodaya Mutually Aided Co- Income Tax Officer, Vs. Ward-8(2), Hyderabad. Operative Thrift Society Ltd., Udamgadda. Pan: Aacan0471H (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Abhiroop Bhargav, C.A. रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 26/08/2025 घोर्णध की तधरीख/Pronouncement: 03/09/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Navodaya Mutually Aided Co- Operative Thrift Society Ltd. (“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 11.12.2024 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri Abhiroop Bhargav, C.AFor Respondent: Shri Gurpreet Singh, SR-DR

Section 142(1)Section 144Section 69A

That on the facts and circumstances of the case, the NFAC/CIT(A) erred in confirming an addition towards unexplained money under section 69A of the Act amounting to Rs.15,28,000/-. 3. The appellant craves leave to add, amend, alter, vary and / or withdraw any or all the above grounds ... completed the assessment under section 144 of the Act on 04.12.2019 by treating the entire bank credits of Rs.2,23,18,124/- as unexplained money under section 69A of the Act. 4. Aggrieved with the order of Ld. AO, the assessee preferred appeal before the Ld. CIT(A). After considering

Sai Enterprises, Hyderabad vs. Income Tax Officer, Ward - 11(3), Hyderabad

ITA 22/HYD/2025[2017-18]Status: DisposedITAT Hyderabad03 Sept 2025AY 2017-18

Bench: Us:

Section 143(3)Section 69A

bank account during the demonetization period, held the entire amount of Rs. 86,37,018/- (supra) as having been sourced out of its unexplained money under Section 69A of the Act. Accordingly, the A.O. vide his order passed under Section 143(3) of the Act, dated 22.12.2019, determined the income ... assessee did not explain the sources of cash deposits made during the demonetisation period, the AO treated the sum of Rs.86,37,018/- as Unexplained Money u/s.69A of the Act. The AO computed the undisclosed business turnover by subtracting the demonetisation cash deposits of Rs.86,37,018/- and the total

Deputy Commissioner of Income Tax, Mumbai vs. Mgn Agro Properties Private Limited, Mumbai

In the result, the appeal filed by the revenue has been rendered as dismissed, in terms

ITA 3759/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Sept 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Harsh Kapadia a/w. Shri AjayFor Respondent: Shri Umashankar Prasad, (CIT DR)

Section 132(4)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 69A

circumstances of the case, the Ld. CIT(A) erred in deleting the addition of Rs.22,00,00,000/- on account of unexplained money u/s.69A of the Income Tax Act, 1961 without fully appreciating the facts of the case." 3. Briefly stated, the facts of the case are that the assessee ... with the following observations: “10. Ground No. 4 pertains to the addition of Rs.22,00,00,000/- made by the AO on account of unexplained money u/s.69A of the Act in respect of alleged cash received by the appellant during the previous year in lieu of an upcoming land sale

Vijay Kumar Gupta, Delhi vs. ITO - Ward 60(3), Delhi

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

ITA 3870/DEL/2025[2017-18]Status: HeardITAT Delhi03 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh[Assessment Year: 2017-18]

Section 115BSection 144Section 44ASection 69A

taxpayer in the two businesses - one in Vinod Traders and another in share commission business. The remaining amount of Rs 3095509 is upheld as unexplained money the nature and source of which could not be satisfactorily explained before the assessing officer/appellate authorities. The addition of Rs 3095509 is upheld

Swati Monga, Delhi vs. Income Tax Officer, Ward 42(5), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1350/DEL/2024[2016-17]Status: DisposedITAT Delhi03 Sept 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(3)Section 44ASection 69A

assessing the total income at Rs. 61,51,770/- with an addition u/s 69A on account of unexplained money of Rs. 54,48,220/- and levied tax thereof at Rs. 24,34,819/-. 5. Being aggrieved, the assessee filed her appeal before the CIT(A) who upheld the additions made ... dismissed. Further with regard to the legal ground that addition u/s 69A is not correct, the fact remains that the appellant had unexplained money in her hands during the year and she deposited the same in her bank accounts. As long as the finding that she had unexplained money

Pavan Kumar Bhagat, Saharsa vs. ITO, Ward-3(4), Saharsa, Sahara

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

ITA 281/PAT/2024[2017-18]Status: DisposedITAT Patna02 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 144Section 147Section 148Section 250Section 37Section 69A

account number 916020006466996) I.T.A. No.: 281/PAT/2024 Assessment Year: 2017-18 Pavan Kumar Bhagat. with Axis Bank, during the demonetization period (09.11.2016 to 30.12.2016) is unexplained money u/s 69A of the Act and assessed the same under Section 115BBE of the Act, notwithstanding the fact that the cash deposits were from

Asit Somabhai Patel, Unjha vs. The ITO, Ward-1, Patan

In the result, the appeal of the assessee is allowed

ITA 695/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2013-14

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Divetia & Shri Samir Vora, ARsFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR

Section 250Section 68Section 69A

whom loan was taken by the assessee was not proven. Accordingly, the Assessing Officer treated the full amount of Rs. 3,50,000/- as unexplained money under Section 69A of the Act and added it to the income of the assessee. 4. The assessee filed appeal before

Shankutlaben Patel, Petlad vs. NFAC, Delhi, the ITO, Ward-1, Anand

In the result, the appeal is allowed for statistical purposes

ITA 1050/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2013-14

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri M J Shah, AR & Shri Rushin Patel ARFor Respondent: Shri Prateek Sharma, Sr. DR

Section 144Section 144BSection 69A

source of the cash deposits, and therefore, by invoking section 69A of the Act, he deemed the amount of Rs. 17,29,639/- as unexplained money and accordingly added the same as income of the assessee for the year under consideration. The assessment was completed Shankutlaben Patel vs. ITO Asst.Year

Incometax Officer, Ward-2(1)(2), Ahmedabad vs. Chaitanya Prakashbhai Dangi, Ahmedabad

In the result, the appeals of both the assessee and the Revenue are allowed for statistical purposes

ITA 771/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Abhijit, Sr. DRFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 234ASection 234BSection 68Section 69A

assessee failed to substantiate the source of such large deposits, the entire sum of ₹55,00,000/- was liable to be treated as unexplained money under section 69A of the Act and accordingly, added the same to income. Accordingly, the total income of the assessee was computed