“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

Dilip Madhav Adling, Pune vs. The Income Tax Officer, Ward-14(5), Pune

Appeal of the assessee is allowed for statistical purposes

ITA 1971/PUN/2024[2017-18]Status: DisposedITAT Pune29 Aug 2025AY 2017-18

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

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

case and in law, Ld CIT(A)/NFAC has erred in considering amount received from Assessees Son of Rs. 5,00,000/- as Unexplained Money u/s 69A r.w.s. 115BBE. 5. Under the facts and circumstances of the case and in law, Ld CIT(A)/NFAC has erred in considering Agricultural ... Receipts in Bank of Rs. 5,21,694/- as Unexplained Money U/s 69A r.w.s. 115BBE. 6. Under the facts and circumstances of the case and in law, Ld CIT(A)/NFAC has erred in considering credits in Saving Bank Account and Loan Accounts of Rs. 13,25,832/-as Unexplained

Santoshkumar Gograj Adukia HUF, Mumbai vs. ITO Ward 41(3)(4), Mumbai

In the result the appeal filed by the assessee stands allowed on merits

ITA 4424/MUM/2025[2012-13]Status: DisposedITAT Mumbai29 Aug 2025AY 2012-13

Bench: Smt. Beena Pillai () I.T.A. No. 4424/Mum/2025 Assessment Year: 2012-13

Section 132Section 133(6)Section 142(1)Section 147Section 148Section 68Section 69ASection 69C

confirming the Action of AO of making additions of Rs.10,00,000/- being loan from M/s. Banas Finance Limited by treating the same as unexplained money under Section 69A. 3. On the facts and circumstances of the case and in law, the Id. CIT(A) has grossly erred in confirming ... assessee of Rs. 10,00,000/- to be bogus and made addition in the hands of the assessee u/s.69A of the Act as unexplained money. The Ld.AO also made addition u/s.69C being the commission 15% on the alleged bogus loan. Aggrieved by the order of the Ld.AO assessee preferred appeal

Shri. Bishmit Singh Chawla, Mumbai vs. Income Tax Officer, Ward 41(4)(1), Mumbai

ITA 4238/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Aug 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Bishmit Singh Chawla Ito Ward 41(4)(1) Coregaon Wine Shop No. Ii Room No. 603 Hanuman Tekdi, Opp. Vs. Kautilya Bhavan Western Express Highway Bandra Kurla Goregaon East Complex, Bandra-E Mumbai-400 063. Mumbai-400 051. Pan : Afapc7509P Appellant Respondent

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri Vimal Punmiya

Section 11Section 115BSection 144Section 147Section 148Section 148ASection 234ASection 270ASection 271ASection 69A

NFAC/ CIT(A) erred in upholding the addition of cash amount of Rs.1,01,79,000/- which is treated as unexplained money of the assessee u/s 69A of the Act and to be taxed as per the provisions of Section 115BBE of the Income ... stock by cash. The cash sale proceeds were deposited in the bank account and hence the cash deposited cannot be treated as “Unexplained money” under section 69 of the I.T. Act. The Ld. AR of the appellant requested this Bench to 4 Bishmit Singh Chawla remand the matter

Nimantran Restaurant Pvt Ltd, Mumbai vs. Income Tax Officer - 15(2)(1), Mumbai

In the result, ITA No.1331/M/2025 is allowed for statistical purposes

ITA 1332/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Aug 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2017-18 & Assessment Year: 2018-19

For Appellant: Shri Satyaprakash Singh, Ld. A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. D.R

Section 143(3)Section 250Section 251(1)(a)Section 251(2)Section 69

assessment order dated 19.12.2019 u/s 143(3) of the Act has been upheld, by which the additions of Rs.62,00,000/- on account of unexplained money u/s 69 of the Act and Rs.3,99,310/- on account of disallowance of expenses were made. The Assessee accepted lapse on his part

Nimantran Restaurant Pvt Ltd, Mumbai vs. Income Tax Officer- 15(2)(1), Mumbai

In the result, ITA No.1331/M/2025 is allowed for statistical purposes

ITA 1331/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Aug 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2017-18 & Assessment Year: 2018-19

For Appellant: Shri Satyaprakash Singh, Ld. A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. D.R

Section 143(3)Section 250Section 251(1)(a)Section 251(2)Section 69

Dy. Commissioner of Income Tax, Noida vs. M/S Rudra Buildwell Homes Pvt. Ltd, Delhi

ITA 602/DEL/2025[2016]Status: DisposedITAT Delhi29 Aug 2025

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Rudra Buildwell Homes Dcit, Central Circle-I, Noida Pvt. Ltd., 53, Okhla Phase, Delhi Pan: Aafcr6959P (Appellant) (Respondent) With C.O. No.106/Del/2025 [Arising Out Of Ita No.602/Del/2025] Assessment Year: 2016-17 M/S. Rudra Buildwell Vs. Dcit, Central Circle-I, Homes Pvt. Ltd., Noida A-66, Sector-63, Noida Pan: Aafcr6959P (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Agarwal, Itp Department By Sh. Rajesh Chandra, Cit(Dr) Date Of Hearing 12.08.2025 Date Of Pronouncement 29.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.602/Del/2025 & Assessee’S Cross Objection C.O. No. 106/Del/2025 For Assessment Year 2016-

Section 143(3)Section 148Section 148ASection 151Section 151(1)Section 151(2)

money which has been credited is the same money which has been advanced in earlier years/during the year, the same cannot be treated as unexplained money in the hands of the appellant. The AO has applied Section 69A to the case of the appellant. Once, the money has been advanced

Income Tax Officer Ward 48(1) New Delhi, Delhi vs. M/S. Chaukers, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 5718/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 115BSection 144Section 69A

assessee in the interest of revenue of the entire cash and credit entries of Rs.4,67,17,233/- in said bank account as unexplained money of the assessee u/s 69A of the Act and further invoked the provisions of section 115BBE of the Act. In first appeal

ITO, Ward-34(1), New Delhi, Civic Center, Delhi vs. Sanchit Dua, New Delhi

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

ITA 1733/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: BEFOREMS. MADHUMITA ROY (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 115BSection 144Section 147Section 69A

assessee. Such addition was made under section 69A of the IT Act further to be taxed under Section 115BBE of the IT Act on unexplained money. Since, the assesse could not submit the response on the date of hearing on 24.03.2022, the same was further added to the income

DCIT Central Circle-06, New Delhi vs. Santosh Trust, New Delhi

ITA 1427/DEL/2023[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Suresh K. Gupta, AdvFor Respondent: Sh. Mahesh Shah, CIT, DR

Section 12ASection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 69ASection 80G(5)(iv)

during the demonetization period was added in the hands of the assessee under Section 69A r.w.s 115BBE of the Act treating the same as unexplained money which was in turn deleted by the First Appellate Authority. Hence, the instant appeal before us. 4. The assessee a charitable trust duly registered ... assessee trust deposited an amount of Rs.39,83,63,741/- in demonetization currency which were treated by the Ld. AO as unexplained money under Section 69A r.w.s 115BBE in the absence of corroborative evidence to justify the source of such deposits which was in turn deleted

Goenka Trading Company, Annupur vs. ACIT Central Circle, Jabalpur

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

ITA 106/JAB/2025[2020-21]Status: DisposedITAT Jabalpur28 Aug 2025AY 2020-21

Bench: Shri Anadee Nath Misshra

Section 143(3)

assessee at Rs.27,50,120/- by making addition of Rs.20,06,437/- on account of unexplained investment and Rs.5,783/- on account of unexplained money. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide impugned order dated 19/02/2025, the assessee’s appeal was dismissed

Gajendra Kumar, Mahoba vs. Income Tax Officer Ward 2 (2)(4 ), Banda

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

ITA 94/ALLD/2025[2017-2018]Status: DisposedITAT Allahabad28 Aug 2025AY 2017-2018

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2017-18 Gajendra Kumar, Vs. Income Tax Officer, 526, Rathaur Colony, Jaitpur, Ward-2(2)(4), Banda Belatal, Mahoba, U.P. Pan:Bitpk6827P (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 06.08.2025 Date Of Pronouncement: 28.08.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A) Passed Under Section 250 Of The Income Tax Act, 1961 On 3.01.2025, Dismissing The Appeal Of The Assessee Against The Orders Of The Ito, Ward-2(2)(4), Banda Dated 21.12.2019 Passed Under Section 144 Of The Income Tax Act. The Grounds Of Appeal Are As Under:- “1. That The Learned Cit (Appeal) Has Erred In Law & Facts In Disallowing Appeal & Confirming The Addition Made By A.O. Of Rs. 25, 90,414/- As Cash Deposits Into Bank Account Under Section 69A Of It Act, 1961 Because All Notices Were Issued U/S 250 Of The Act On Itba Portal & No Physical Notice Was Issued To Appellant On Address Mentioned In Filed Itr & Filed Appeal & Has Disallowed Appeal Without Considering This Fact That Appellant Lives At Village Jaitpur Post Belataal, District Mahoba (U.P.) & Is Unknown About Information Technology. 2. That The Learned Cit (Appeal) Has Erred In Law & Facts In Disallowing Appeal & Confirming The Addition Made By A.O. Of Rs. 25, 90,414/- As Cash Deposits Into Bank Account Under Section 69A Of It Act, 1961 Without Considering This Fact That Appeal Was Filed By Advocate Dinesh Gupta Who Was Expired & Email Id In Profile Of Appellant Was Update By Him. Appellant Was Unknown About Login Id & Password Of Portal & Email Id Which Was Maintained By Late Advocate Dinesh Gupta.

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. A.K. Singh, Sr. DR

Section 142Section 142(1)Section 143(2)Section 144Section 221(1)Section 250Section 69A

assessee to submit explanation with regard to the credits, the ld. AO held that the remaining money deposited into the bank account was unexplained money under section 69A of the Income Tax Act and he brought the same to tax under section 115BBE @ 60%. 4. Aggrieved with the said assessment

Inder Kumar Nigotiya, Jaipur vs. ITO Ward, 1 (1), Jaipur

The appeal of the assessee is allowed

ITA 1011/JPR/2025[2017-2018]Status: DisposedITAT Jaipur28 Aug 2025AY 2017-2018

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

For Appellant: Sh. Rajeev Sogani, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 115BSection 139(1)Section 143(2)Section 143(3)Section 69A

treating the subsequent interest income earned on Money Lending Transaction declared under IDS, 2016 amounting to Rs. 11,01,370 as unexplained money u/s 69A of the Act. The action of the Id. ADDL/JCIT(A) in confirming the action of Id. AO is illegal, unjustified, arbitrary and against the provisions ... treating the interest income earned on Money Lending declared under IDS, 2016 amounting to Rs. 11,01,370 as unexplained money u/s 69A of the Act, and invoking the provision of section 115BBE. The action of the Id. ADDL/JCIT(A) in confirming the action of ld. AO is illegal, unjustified

Sandeep Kumar Chaurasiya, Faizabad vs. Income Tax Officer - 1, New Faizabad, Faizabad

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

ITA 742/LKW/2024[2015-16]Status: DisposedITAT Lucknow28 Aug 2025AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 144Section 147Section 250(6)Section 69A

assessee at I.T.A. No.742/Lkw/2024 Assessment Year:2015-16 2 Rs.14,06,210/- by making addition of Rs.12,30,000/- on account of unexplained money under section 69A of the Act. The order passed by the Assessing Officer was an ex-parte order qua the assessee. Being aggrieved, the assessee filed

Income Tax Officer, Ward-5(1), Kolkata vs. Expression Novelties Private Limited, Kolkata

In the result, the appeal filed by the Revenue is dismissed while the Cross Objections filed by the assessee are also dismissed as withdrawn

ITA 1351/KOL/2025[2017-18]Status: DisposedITAT Kolkata28 Aug 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

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

allowing the appeal of the assessee by deleting the addition of Rs. 68,50,000/- made u/s 69A of the Act on account of unexplained money without going through the merits of the case in that the assessee failed to furnish any plausible explanation regarding the deposit of huge cash ... assessee Company at Rs.86,08,770/- after adding Rs.68,50,000/- being cash deposited during the demonetization period which was considered as unexplained money u/s. 69A of the I.T. Act, 1961. 4. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who, vide order

Nalla Thambi, Tiruchirapalli vs. ITO, Ward-1(2), Trichy

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

ITA 1729/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.1729/Chny/2025 िनधा"रण वष" /Assessment Year: 2017-18

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Mrs. R. Anitha, Addl. CIT

Section 143(3)Section 69A

order passed u/s. 143(3) of the Act, the Assessing Officer made an addition u/s. 69A of the Act treating the said deposits as unexplained money. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A). However, the Ld. CIT(A), by passing an ex-parte order, confirmed

Hina Kauser, Bangalore vs. Income Tax Officer, Ward-1(2)(5), Bangalore

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

ITA 858/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Aug 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Respondent: Mr. Syed Ashfaq Ahmed

Section 142(1)

year and the cash withdrawals. The assessee had not responded to the notices issued u/s. 142(1) and therefore the AO had added the unexplained money in the bank accounts as income. As against the said order, the assessee filed an appeal before the Ld.CIT(A). The assessee filed

Hanumanthappa Govindappa, Bangalore vs. ITO, Ward 3(3)(1), Bangalore

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

ITA 610/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Aug 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Rakesh, CAFor Respondent: Shri Balusamy .N, JCIT-DR

Section 133(6)Section 139Section 142(1)Section 148Section 69A

cash deposits as unexplained investment money u/s. 69A of the Act. The AO also treated the fixed deposits made in the Canara Bank as unexplained money u/s. 69A of the Act. Similarly, the salary / pension was also added to the income of the assessee. As against the said order

Reddivari Subba Reddy(HUF), Bellary vs. Income Tax Officer, Ward-2, Bellay

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

ITA 344/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Aug 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Reddivari Subba Reddy (Huf), Vs. Ito, D.No.44, Behind Maremma Temple, Ward – 2, Kappagal Road, Near Hdfc Bank, Bellary. Bellary – 583 103. Pan : Aaohr 4185 D Appellant Respondent Assessee By : Shri. V. Srinivasan,Advocate Revenue By : Shri. Ganesh R. Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 17.07.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. V. Srinivasan,AdvocateFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue

Section 115BSection 133(6)Section 142(1)Section 144Section 69A

during demonetization period was deposited by the assessee. The assessee had no other source of income. Therefore, it cannot be said that it is unexplained money. The learned Counsel furnished Paper Book containing Pages 1 to 42 and in Page No.17 has furnished details of the cash withdrawal and deposits

ACIT 7(1)(1), Mumbai vs. Longseal Machinery Pvt Ltd., Mumbai

ITA 5523/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: NoneFor Respondent: Shri Rajesh Kumar Yadav, CIT DR

Section 143(3)

erred in deleting the addition of Rs.8,07,55,300/- made by the AO treating the same as unexplained money without appreciating the facts that the assessee has failed to submit documentary evidence to prove the genuineness of the said transaction. 2. Whether on the facts and in the circumstances ... erred in deleting the addition of Rs.22,84,92,464/- made by the AO treating the same as unexplained money without appreciating the facts that the assessee has failed to submit any document/agreement entered with M/s Emporis Projects Ltd. with regard to distribution of loss incurred from sale of investment

Surya Roshni Limited, New Delhi vs. Principal Commissioner of Income Tax - 7, New Delhi

ITA 1444/DEL/2024[2015-16]Status: DisposedITAT Delhi28 Aug 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(3)Section 147Section 148Section 263Section 263(1)

making addition of INR 11,01,50,000/- being the amount received from five share applicant companies from time to time as the unexplained money of the assessee. Ld.AR submits that assessee had filed detailed reply on 09.05.2018, copy of the notice issued u/s 154/155 of the Act alongwith