“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

Manubhai Babalbhai Patel, Vadodara vs. The ITO, Ward-1(2)(1), Vadodara

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

ITA 605/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DRFor Respondent: Shri R P Rastogi, CIT-DR

Section 144BSection 147Section 250Section 69A

assessee could not substantiate his explanation or provide credible evidence. Accordingly, the Assessing Officer treated the entire amount of ₹3,32,62,000/- as unexplained money under Section 69A of the Act and added the same to the total income of the assessee. 5. In appeal before CIT(Appeals

Chaitanya Prakashchandra Dangi, Ahmedabad vs. The ITO, Ward-2(2)(1), Ahmedabad

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

ITA 570/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

Income Tax Officer, Ward-1, Perambalur vs. A Kulanthaivel, Malayalapatty

ITA 903/CHNY/2025[2019-20]Status: DisposedITAT Chennai02 Sept 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita Nos.902 & 903/Chny/2025 िनधा;रण वष; /Assessment Years: 2018-19 & 2019-20

For Respondent: Shri Shiva Srinivas, CIT

also accounted in the books of the HUF, I am of the considered view that the addition of Rs 4,66,49,320 as unexplained money u/s 69A of the Act in the hands of the appellant is not sustainable and is directed to be deleted. The appeal on Ground

Income Tax Officer, Ward-1, Perambalur vs. A. Kulanthaivel, Malayalapatty

ITA 902/CHNY/2025[2018-19]Status: DisposedITAT Chennai02 Sept 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita Nos.902 & 903/Chny/2025 िनधा;रण वष; /Assessment Years: 2018-19 & 2019-20

For Respondent: Shri Shiva Srinivas, CIT

Girish Chandra, Patna vs. ITO, Ward- 4(3), Patna

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

ITA 615/PAT/2024[2016-17]Status: DisposedITAT Patna01 Sept 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.615/Pat/2024 Assessment Year: 2016-17 Girish Chandra……………………………. …………………....Appellant S/O Harsukh Rai Vyas, Nai Sarak, 11/A Devaki Complex, Chowk Patna City, Patna-800008. [Pan: Afrpc1879H] Vs. Ito, Ward-4(3), Patna……..……………..………………….…..... Respondent Appearances By: Shri Pradeep Kr., Ca Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 07.12.2023 Passed By The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-1, Delhi Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 253 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 250Section 69A

statutory requirements. Due to non-compliance, the Assessing Officer on perusal of the bank statements a sum of Rs.37,287/- was treated as unexplained money under Section 69A of the Act and added the same to the total income of the assessee. 4. Aggrieved, the assessee preferred an appeal before

Bipin Kumar, Vaishali vs. ITO Ward 1(3), Vaishali

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

ITA 463/PAT/2024[2017-18]Status: DisposedITAT Patna01 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.463/Pat/2024 Assessment Year: 2017-18 Bipin Kumar….……………………………. …………………....Appellant Patepur Paura Kartaha Vaishali Bihar 844117, Bihar-844117. [Pan: Bnepk5098Q] Vs. Ito, Ward-1(3), Vaishali.…..……………..………………….…..... Respondent Appearances By: Shri Ravi Shankar, Adv., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 05.01.2024 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That Notice U/S 142(1) Of The Act Was Issued For Calling Return Of Income For The Assessment Year 2017-18. However, The Assessee Failed To Furnish His Return Of Income For The Assessment Year In Question Either U/S 139 On Or Before 31.03.2018 & Failed To Furnish Itr In Response To Notice Issued U/S 142(1) Of The Act. Later On, The Assessing Officer Got Information That The Assessee Has Deposited Total Cash Amounting To Rs.83,67,203/- In His Bank Account During The Demonetisation Period. As There Was No Compliance On Behalf Of The Assessee, The Assessing Officer Treated The Entire Cash

Section 115BSection 139Section 142(1)Section 250Section 69A

compliance on behalf of the assessee, the Assessing Officer treated the entire cash I.T.A. No.463/Pat/2024 Bipin Kumar deposits of Rs.83,67,203/- as unexplained money under Section 69A of the Act and taxed the same u/s 115BBE of the Act. 3. Aggrieved by the above order, the assessee preferred

Govind Jee, Jaipur vs. ITO Ward -1(1), Jaipur

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

ITA 1040/JPR/2025[2017-18]Status: DisposedITAT Jaipur01 Sept 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri R.S. Poonia,CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 69A

addition of Rs.12,76,500/- to the income 5 SHRI GOVIND JEE VS ITO, WARD 1(1), JAIPUR of the assessee deeming it as unexplained money u/s 69A of the Act and total income assessed was taxed u/s 115BBE of the Act, at the rate of 60%. In first appeal

Annamalai, Tiruvallur vs. ITO, Ward-1, Vellore

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

ITA 1386/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1386/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Shri Annamalai, The Income Tax Officer, 22, I Street, Thundalam, Vs. Ward 1, Vijayalakshmi Nagar, Vellore. Chettiyaragaram, Ayappakkam, Chennai – 600 077. Pan: Bcjpa 0560P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 01.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 01.09.2025

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 115BSection 144Section 250Section 69A

income admitting income of Rs.3,57,740/-. The AO completed the assessment u/s.144 of the Act by making addition of Rs.7,99,500/- as unexplained money u/s.69A of the Act and taxed the same at special rate u/s.115BBE of the Act. Aggrieved, assessee preferred appeal before the First Appellate Authority

Safari Sales and Services, Jabalpur vs. ITO Ward 1, Satna

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

ITA 101/JAB/2025[2017-18]Status: DisposedITAT Jabalpur29 Aug 2025AY 2017-18

Bench: Shri Anadee Nath Misshra**

Section 144BSection 147Section 249(2)Section 249(3)Section 69A

short) and determined the total income of the assessee at Rs.29,12,120/- by making addition of Rs.29,12,120/- on account of unexplained money u/s 69A of the Act. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide impugned order dated 26/03/2025, the assessee

Shri Ishwari Prasad Awasthi, Chhatarpur vs. Income Tax Officer, Chhatarpur

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

ITA 41/JAB/2024[2017-18]Status: DisposedITAT Jabalpur29 Aug 2025AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 143(3)

assessee at I.T.A. No.41/JAB/2024 Assessment Year:2017-18 2 Rs.9,92,865/- by making addition of Rs.5,70,625/- on account of unexplained money. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide impugned order dated 30/01/2024, the assessee’s appeal was dismissed

Ramkrishna Arjariya, Chhatarpur vs. Income Tax Officer, Chhatarpur

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

ITA 162/JAB/2024[2017-18]Status: DisposedITAT Jabalpur29 Aug 2025AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 111Section 147Section 69A

short) and determined the total income of the assessee at Rs.15,00,000/- by making addition of Rs.15,00,000/- on account of unexplained money u/s 69A of the Act. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide I.T.A. No.162/JAB/2024 Assessment Year

Jigneshbhai Sa vs. Ibhai Khorani, Surendranagarvs.Income Tax Officer, Ward -1, Surendranagar

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

ITA 54/RJT/2025[2013-14]Status: DisposedITAT Rajkot29 Aug 2025AY 2013-14

Bench: Shri Dr. A. L. Saini, Accountat Member & Shri Dinesh Mohan Sinhaarray Ard S/Ita No.54/Rjt/2025 Assessment Year: (2013-14) (Physical Hearing)

Section 147Section 274Section 69A

decision of learned Assessing Officer has erred in law and on facts by treating the entire cash deposit of Rs.52,82,320/- as "unexplained money" under Section 69A of the Income Tax Act, 1961, without properly investigating the appellant's claim of account misuse. ITA.54/RJIT/2025/A Y.2013-14 Jigneshbhai Savjibhai Khorani ... based on the material available on record. The AO made addition of Rs.52,82,320/- u/s 69A of the Act and treated as unexplained money. The AO also initiated penalty proceedings u/s 274 r.w.s. 271(1)(c) of the Act. 4. Aggrieved by the order of AO, the assessee filed

Ghanshyambhai Mohanbhai Patel, at Po Umarda vs. Income Tax Officer Ward 4 Surendranagar, Income Tax Office Irish Building

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

ITA 382/RJT/2025[2017-18]Status: DisposedITAT Rajkot29 Aug 2025AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 382/Rjt/2025 ("नधा"रण वष" / Assessment Year: (N.A.) (Hybrid Hearing) Ghanshyambhai Mohanbhai Patel Income Tax Officer, Ward-4, Surendranagar, Income Tax Near Swaminarayan Mandir, At Umarda, Vs. Office, Irish Building, Opp. Mela Ta.Muli, Dist. Surendranagar-363 510 Medan, Surendranagar-363 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Brjpp 6166 K (Appellant) (Respondent)

For Appellant: Shri Pinal Raval, Ld. ARFor Respondent: Shri Abhimunyu Singh Yadav, Sr.D.R

Section 142(1)Section 144Section 250Section 69A

allegation of unexplained cash based on negative balance is factually incorrect. 2 Ghanshyambhai M Patel * Addition of ?5,14,863 u/s 69A as Unexplained Money: The addition under Section 69A is unjustified. The AO has ignored the evidence of purchases made from Gujarat Agro Industries and Sahakari Society Ltd. - institutions ... Rs.5,14,863) The CIT(A) erred in law and on facts in confirming the addition of Rs.5,14,8637- under Section 69A as unexplained money, without appreciating the appellant's explanation regarding the opening cash balance, business cash flows, and other financial records already submitted to the Assessing Officer

Bhaveshkumar Mahendrabhai Maniyar, Junagadh vs. The ITO Ward-1, Junagadh.

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

ITA 234/RJT/2025[2019-20]Status: DisposedITAT Rajkot29 Aug 2025AY 2019-20

Bench: Shri Dr. A. L. Saini, Accountat Member & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.234/Rjt/2025 Assessment Year: (2019-20) (Physical Hearing) Bhavneshkumar Mahendrabhai Vs. Ito, Maniyar, Ward – 1, Prop.Of Shree Hari Enterprise, Junagadh Shop No.2, Rajkamal Apartment, Junagadh, Junagadh - 362001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afdpm3866Q (Appellant) (Respondent)

Section 132Section 133ASection 147Section 250Section 253(3)Section 253(5)

money payment, therefore, unaccounted on-money payment of Rs.28,00,000/- was treated as income in the hands of the assessee as unexplained money ITA.234/RJT/2025/AY.2019-20 Bhaveshkumar Mahendrabhai Maniyar u/s 69A r.w.s. 115BBE of the Act and added to the total income of the assessee. The AO made addition of Rs.28

Tulsi Jewellers, Na vs. Arivs.Income Tax Officer - Ward 5, Navsari

In the result assessee's appeal is allowed

ITA 947/SRT/2024[2017-18]Status: DisposedITAT Surat29 Aug 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

Section 115BSection 144Section 147Section 148Section 148ASection 250Section 271ASection 69A

reply or explained the source of cash deposited in demonetized currency. Therefore, the aforesaid cash deposits of Rs.13,20,000/- was treated as unexplained money and accordingly, the addition of Rs.13,20,000/- was made u/s.69A of the Act. The total income of the assessee was assessed at Rs.13

Tulsi Jewellers, Na vs. Arivs.Income Tax Officer, Ward 5, Navsari

In the result assessee's appeal is allowed

ITA 946/SRT/2024[2017-18]Status: DisposedITAT Surat29 Aug 2025AY 2017-18

Section 115BSection 144Section 147Section 148Section 148ASection 250Section 271ASection 69A

Pakalapati Padma Jyothi, West Godavari Dist vs. Income Tax Officer, Ward-1, Tadepalligudem

In the result, appeal of the assessee is allowed

ITA 275/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam29 Aug 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.275/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Pakalapati Padma Jyothi V. Income Tax Officer – Ward – 1 D.No. 1-17, Singarajupalem Income Tax Office Muthyalamma Gudi Street Aayakar Bhawan Avapadu, Nellajerla D.No. 2-1-56/1, K.N. Road West Godavari District Tadepalligudem – 534101 Andhra Pradesh [Pan:Blwpp5193B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr.Ar

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

Rs.7,63,790 made by the assessing officer u/s 69A of the Act by treating the amount received from Margadarsi Chit Fund as unexplained money. 4. Any other ground that may be urged at the time of appeal hearing.” 5. Assessee also raised the following additional grounds and prayed

G S Real Estate and Allied Limited, Indore vs. Income Tax Officer 1- Dewas, Dewas

Appeal of the assessee is allowed for statistical

ITA 222/IND/2025[2017-18]Status: DisposedITAT Indore29 Aug 2025AY 2017-18

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2017-18

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 253Section 69A

Since the appellant did not provide any explanation or details regarding the share application money, it was treated as unexplained money under section 69A and section 115BBE, and added to the total income for the year. 6.2 The appellant's grounds are found to be untenable due to the fact ... Page 4 of 8 G.S Real Estate and Allied Ltd. A.Y. 2017-18 amounting to Rs. 1,06,21,000/-by treating it as unexplained money under section 69A read with section 115BBE of Income Tax Act, 1961. The addition made is totally wrong and illegal on facts

Gyan Prakash Tiwari, Rajgarh vs. ITO, Shajapur

In the result appeal of the assessee is partly allowed

ITA 563/IND/2024[2009-10]Status: DisposedITAT Indore29 Aug 2025AY 2009-10

Bench: Shri Manish Boradgyan Prakash Tiwari, Income Tax Officer, Talab Mohalla Chhapiheda, Shajapur Vs. Rajgarh (Appellant / Assessee) (Respondent/ Revenue) Pan: Abupt8470C Assessee By Ms. Ruchira Nerkar, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 29.08.2025 O R D E R

Section 142(1)Section 143(3)Section 263

assessee's father Shri Hiralal Tiwari. The source of same was out of agricultural income. AO had added Rs.9,00,000/ as unexplained money, as no satisfactory reply received from appellant. Appellant had not furnished copies of income tax return filed by appellant's father indicating that agricultural income reported

Mr Chandrashekhar Vinayak Nimhan, Pune vs. ACIT, Circle-2, Pune

Appeal of the assessee is allowed for statistical purpose

ITA 1992/PUN/2024[2017-18]Status: DisposedITAT Pune29 Aug 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

Section 143(3)Section 250Section 3Section 44ASection 69A

made by the Assessing Officer on account of cash deposited in the bank accounts during the demonetization period, by treating the same as unexplained money in the hands of the assessee. 2. The order of the Ld. Commissioner of Income Tax (Appeals) has been passed in violation of the principles