“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

Dhananjay Proprietor of M/S Innovative Business Solutions, New Delhi vs. ITO Ward 51(2), New Delhi

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

ITA 3893/DEL/2023[2017-18]Status: DisposedITAT Delhi28 Aug 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldhananjay Prop. Of M/S Income Tax Officer, Innovative Business Ward-51(2), Solution, 2097/A-1, Vs. Delhi. Gali No.15, Near Govt. School, Prem Nagar, Patel Nagar, New Delhi-110008. Pan:Ambpd2549L (Appellant) (Respondent) Assessee By Shri Mayank Sharma, Adv. Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R [ Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A) In Short], Dated 07.11.2023 In Appeal No. Cit(A), Delhi-17/11006/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 (The Act, In Short) For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Prop. Of M/S Innovative Business Solutions Engaged In The Business Of Providing Business Solutions. The Return Of Income In The Year

Section 250Section 68

sales, therefore, the deposit in 3. ITA No.3893/Del/2023 Dhananjay Prop. Of M/s Innovative Business Solutions vs. ACIT SBN should not be treated as unexplained money u/s 68 of the Act. He prayed for deletion of the addition made on this account. 6. On the other hand, Ld. CIT-DR supports

Amraram Gomaji Chowdhary, Navelim vs. Income Tax Officer, Ward - 1, Margao

ITA 117/PAN/2025[2018-19]Status: DisposedITAT Panaji27 Aug 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 117/Pan/2025 Assessment Year : 2018-19 Amraram Gomaji Chowdhary 457/C, Aquem Baixo, Firgulem, Navelim, Goa-403707. Pan : Aqjpc0124C . . . . . . . Appellant V/S Income Tax Officer, Ward-(1), Margao, Goa. . . . . . . . Respondent Appearances Assessee By : Mr Pradeep Kulkarni [‘Ld. Ar’] Revenue By : Ms Manju Thakur [‘Ld. Dr’] Date Of Conclusive Hearing : 26/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Appellant Assessee Impugns Din & Order Itba/Nfac/S/250/2024-25/1074431239(1) Dt. 12/03/2025 Passed By The National Faceless Appeal Centre, Delhi [‘Ld. Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 29/02/2024 Passed U/S 147 R.W.S. 144B Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Year 2018-19 [‘Ay’ Hereinafter].

For Appellant: Mr Pradeep Kulkarni [‘Ld. AR’]For Respondent: Ms Manju Thakur [‘Ld. DR’]

Section 133(6)Section 147Section 148Section 246ASection 250Section 253(1)Section 69A

explain nature & source of cash deposits made into C/A maintained with ‘Andhra bank’ was made to the total income of the assessee as unexplained money u/s 69A of the Act. Aggrieved by the addition the assessee filed appeal u/s 246A of the Act before the Ld. NFAC who after partly ... presumptive taxation. In the event the Ld. AO brought to tax the entire amount of confirmed cash deposits of ₹60,58,430/- as the unexplained money u/s 69A of the Act and made the addition on such account. 6. We also note that, in the first appellate proceedings, the appellant

Ahmed Lakadia, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

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

ITA 498/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad27 Aug 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Varis Isani, AdovcateFor Respondent: Shri Abhijit, Sr. DR

Section 10(38)Section 115BSection 142(1)Section 147Section 271(1)(C)Section 68

aside. 5. The Lrd. Appellant Authority has erred in law in confirming the addition made u/s. 68 of the IT Act considerate unexplained money. The action of the appellant authority is highly unjustifiable and unlawful. 6. The Lrd. Appellant Authority has erred in law in confirming re-opening

Jyoti Singla, Delhi vs. ITO, Ward-28(4), Delhi, New Delhi

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

ITA 4019/DEL/2025[2012-13]Status: DisposedITAT Delhi27 Aug 2025AY 2012-13

Bench: Shri M. Balaganeshjyoti Singhla, Vs. Ito, 101, Arjun Nagar, Ward-28(4), New Delh Delhi Pan: Anups5253J Assessee By : Shri Neeraj Magla, Ca Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 11/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: Shri Neeraj Magla, CAFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142(1)Section 144Section 148Section 151Section 69A

file any reply therein. Accordingly, the Learned AO proceeded to add the entire cash deposits in the sum of Rs 26,13,600/- as unexplained money under section 69A of the Act and completed the assessment under section 144 of the Act on 04-12-2019. 5. Before the Learned

Praveen Kumar Aggarwal, Delhi vs. ITO, Ward-29(4), Delhi

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

ITA 4018/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shri M. Balaganeshpraveen Kumar Aggarwal, Vs. Ito, 101, Arjun Nagar, New Ward-29(4), Delhi Delhi Pan: Adopa9261C Assessee By : Shri Neeraj Mangla, Ca Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 11/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Shri Manoj Kumar, Sr. DR

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

therein. Accordingly, the Learned AO proceeded to add the entire credits in the bank account in the sum of Rs 21,60,259/- as unexplained money under section 69A read with section 115BBE of the Act and completed the assessment under section ... heed to the contentions of the assessee and sustained the addition of Rs. 14,73,000 being the cash deposited during demonetization period as unexplained money under Section 69A read with Section 115BBE of the Act. Further, the Learned NFAC confirmed the addition of Rs. 1,95,500/- on account

Gurcharan Singh, Panipat vs. Income Tax Officer, Panipat

In the result, the appeal of the assessee is allowed

ITA 3412/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shri M. Balaganeshgurcharan Singh, Vs. Income Tax Officer, Village Urlana Khurd, Ward No. 1, Panipat, Urlana Kalana, Matlodha, Distt Panipat-132103 Pan: Dvbps8866P Assessee By : None Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 14/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: NoneFor Respondent: Shri Manoj Kumar, Sr. DR

Section 115BSection 131Section 133(6)Section 142(1)Section 144Section 69A

lakhs made in the bank account, a sum of ₹5,15,000/- was deposited during the demonetization period which alone was treated as unexplained money u/s 69A read with section 115BBE of the Act by the ld AO and the additions made in the assessment. 4. The assessee filed ... stood properly explained, including the cash deposits made during demonetization period. Hence, there is no scope for treating any part of the deposit as unexplained money u/s 69A r.w.s. 115BBE of the Act. The addition made u/s 69A is here by directed to be deleted. Further, I also find that

Mahayana Theravada Vajrayana Buddhist Religious and Chaitable Trust, Meerut vs. ACIT Central Circle, Meerut

ITA 1709/DEL/2024[2015-16]Status: DisposedITAT Delhi27 Aug 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR

Section 142(1)Section 143(3)Section 147Section 68

Private Limited linked to M/s Salasar Enterprises. Finally the addition was made in the hands of the assessee treating the same as undisclosed and unexplained money under Section 69 of the Act which was further upheld by the First Appellate Authority. Hence, the instant appeal before us. 7. We have

Mahayana Theravada Vajrayana Buddhist Religious and Charitable Trust, Meerut vs. ACIT Central Circle, Meerut

ITA 1708/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR

Section 142(1)Section 143(3)Section 147Section 68

Mahayana Theravada Vajrayana Buddhist Religious and Charitable Trust, Meerut vs. ACIT, Central Circle, Meerut

ITA 1682/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Aug 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR

Section 142(1)Section 143(3)Section 147Section 68

Ravikant Khare, Tikamgarh vs. Income Tax Officer Ward, Tikamgarh

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

ITA 37/JAB/2025[2013-14]Status: DisposedITAT Jabalpur26 Aug 2025AY 2013-14

Bench: Shri Anadee Nath Misshra

Section 143(3)Section 249(2)Section 249(3)Section 69A

short) and determined the total income of the assessee at Rs.8,21,120/- by making addition of Rs.2,15,000/- on account of unexplained money u/s 69A of the Act and Rs.4,26,000/- on account of unexplained money u/s 69A of the Act. Being aggrieved, the assessee filed appeal

Chhaya Masurkar, Balaghat vs. NFAC, ITO Balaghat, Balaghat

In the result, the appeal of the assessee is dismissed

ITA 61/JAB/2024[2013-14]Status: DisposedITAT Jabalpur26 Aug 2025AY 2013-14

Bench: Shri Anadee Nath Misshrachhaya Masurkar V. National Faceless Appeal 1, Ward No. 9, Ram Mandir Center (Nfac) Road, Katangi, Balaghat (Mp)- Delhi (Jurisdiction Officer, 481445. Income Tax Officer, Balaghat (Mp)-110001. Pan:Cakpm8662A (Appellant) (Respondent) Appellant By: Shri Vijay Bagrecha, Ca Respondent By: Shri Alok Bhura, Sr. Cit(Dr) O R D E R (A) The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac)- Delhi, Dated 23.02.2024 For The Assessment Year 2013-14. The Grounds Of Appeal Of The Assessee Are As Under: -

For Appellant: Shri Vijay Bagrecha, CAFor Respondent: Shri Alok Bhura, Sr. CIT(DR)

Section 143(3)Section 250Section 271(1)(c)Section 50CSection 69A

Assessing Officer on account of income from capital gain u/s 50C of the Act. Further, addition of Rs.2,00,500/- on account of unexplained money u/s 69A of the Act. The assessee’s appeal against the aforesaid assessment order was dismissed by the Ld. CIT(A) vide impugned appellate order

Syed Izazul Haque, Guwahati` vs. Income Tax Officer, Ward-3(4), Guwahati

In the result, the appeal of the assesseeis allowed

ITA 284/GTY/2019[2014-15]Status: DisposedITAT Guwahati26 Aug 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Ito, Ward 3(4), Guwahati Syed Izazul Haque Aaykar Bhavan, G.S Road, House No.21, Near Darandamaszid, Panjabari Road, Christian Basti, Guwahati Vs. Guwahati-781037, Assam Pin-781005, Assam (Appellant) (Respondent) Pan No. Aedph2934M Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Kausik Ray, Dr Date Of Hearing: 10.07.2025 Date Of Pronouncement: 26.08.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Kausik Ray, DR

Section 115Section 142(2)Section 144

time to furnish the details, but even on the date appointed for hearing, no evidences were submitted.Finally, the AO treated the capital introduced as unexplained money in the hands of the assessee and added to the income of the assessee and charged tax u/s 115 BBE of the Act,vide

Mr. Agnelo Socorro Joaquim Viegas, Panaji vs. Income Tax Officer, Ward - 1(5), Panaji

ITA 69/PAN/2025[2011-12]Status: DisposedITAT Panaji26 Aug 2025AY 2011-12

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 069/Pan/2025 & Sa 06/Pan/2025 Assessment Year : 2011-12 Agnelo Socorro Joaquim Viegas H. No. 373, Galliwaddo, Taleigao, Caranzalem, Goa-403002. Pan : Akapv9049C . . . . . . . Appellant V/S Income Tax Officer, Ward-1(5), Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr Vinesh Pikale [‘Ld. Ar’] Revenue By : Mr Sanket Deshmukh[‘Ld. Dr’] Date Of Conclusive Hearing : 21/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order No. Itba/Apl/S/250/2024-25/1073026397(1) Dt. 07/02/2025 Passed By Addl./Jt. Commissioner Of Income Tax, Appeals(2), Ahmedabad [‘Ld. Cit(A)’] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’] Which In Turn Sprung Out Of Order Of Assessment Dt. 27/12/2018 Passed U/S 143(3) R.W.S. 147 Of The Act By The Income

For Appellant: Mr Vinesh Pikale [‘Ld. AR’]For Respondent: Mr Sanket Deshmukh[‘Ld. DR’]

Section 143(3)Section 147Section 148Section 246ASection 250Section 253(1)Section 44ASection 5ASection 69A

deposits (₹13,00,000/- minus returned income ₹1,53,590/-) a solitary addition of ₹11,46,410/- was made to the total income as unexplained money u/s 69A of the Act. Aggrieved by the former addition the assessee filed an appeal u/s 246A of the Act before ... disbelieved the assessee’s explanation & declaration with respective presumptive taxation. In the event the Ld. AO treated the entire cash deposit as unexplained money u/s 69A of the Act and brought same to tax after allowing credit for income already declared in the return of income filed in response

Ganesh Kumar Paidi, Vijayawada vs. Income Tax Officer, Ward-2(4), Vijayawada

Appeal is allowed in terms of our aforesaid observations

ITA 135/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam26 Aug 2025AY 2017-18

Bench: Us:

Section 115BSection 143(3)Section 250

therefore, the A.O. held the same as having been sourced out of his unexplained money u/s 69A of the Act. Accordingly, the A.O. vide his order u/s 143(3) of the Act, dated 24.12.2019, determined the income of the assessee at Rs.81,17,210/-. 9. Aggrieved, the assessee carried ... rejected unless under specific conditions and circumstances. In view of this, I believe the action of the AO in bringing to tax, the unexplained money of Rs. 73,95,320/- u/s. 69A cannot be faulted. Hence, the grounds of appeal are dismissed and addition

The Kattoor Service Cooperative Bank Limited, Thrissur vs. Income Tax Officer, Ward 2(1), Thrissur

In the result, the appeals filed by the assessee stand dismissed

ITA 561/COCH/2025[2016-17]Status: DisposedITAT Cochin26 Aug 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69ASection 80P

constrained to make best judgement assessment u/s. 144 of the Act assessing the cash deposit of Rs. 25,88,71,177/- as unexplained money of the appellant vide order dated 25.03.2022 passed u/s. 147 r.w.s. 144 r.w.s. 144B of the Act. 5. Being aggrieved, an appeal was filed before

The Kattoor Service Cooperative Bank Limited, Thrissur vs. Income Tax Officer, Ward 2(1), Thrissur

In the result, the appeals filed by the assessee stand dismissed

ITA 560/COCH/2025[2015-16]Status: DisposedITAT Cochin26 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69ASection 80P

The Kattoor Service Cooperative Bank Limited, Thrissur vs. Income Tax Officer, Ward 2(1), Thrissur

In the result, the appeals filed by the assessee stand dismissed

ITA 559/COCH/2025[2014-15]Status: DisposedITAT Cochin26 Aug 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69ASection 80P

Sai Motors, Indore (M.P.) vs. The Income-Tax Officer, Khargone

In the result appeal of the assessee is partly allowed for

ITA 177/IND/2025[2017-18]Status: DisposedITAT Indore26 Aug 2025AY 2017-18

Bench: Shri Manish Boradsai Motors, Income Tax Officer, C/O Sv Agrawal & Associates, Khargone 25, Joy Builders Colony, Near Rafeal Tower, Vs. Old Palasia, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Acyfs6381E Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 25.08.2025 Date Of Pronouncement 26.08.2025 O R D E R

Section 115BSection 131Section 133(6)Section 143(1)Section 144Section 249(3)Section 44ASection 69A

appellant on account of cash deposited in the bank account during the demonetization period in old notes (SBNs) by treating it as unexplained money R under section 69A of the Income-Tax Act, 1961 and consequently charged tax at the rates prescribed under section 115BBE of the Income

Ajit Singh, Patiala vs. ITO, Patiala

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

ITA 158/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh26 Aug 2025AY 2012-13

Bench: Us, The Ld. Counsel For The Assessee Has Submitted An Application For Condonation Of Delay Along With An Affidavit, Which Is Reproduced As Under:-

For Appellant: None (Adjournment Rejected)For Respondent: Smt. Surinder Kaur Waraich, Addl. CIT

Section 143(3)Section 147Section 148Section 69A

deposits with cogent evidence, the Assessing Officer made an addition of ₹16,19,000/- u/s 69A of the Act, treating the same as unexplained money and completed the assessment u/s 143(3) r.w.s. 147 of the Act vide order dated 11.12.2019. 6. Aggrieved, the assessee preferred an appeal before

Pushpakant Punjalal Chokshi, Anand vs. The ITO, Ward-1(3)(1), Petlad

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

ITA 739/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad26 Aug 2025AY 2012-13

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 739/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ Pushpakant Punjalal The Income Tax Officer Chokshi Ward 1(3)(1), Petlad Vs. Prop: Chokshi Punjalal Somchand & Sons, Jawahar Road, Cambay, Anand – 388620, Gujarat "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agtps8836P (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri M K Patel, Advocate ""यथ" क" ओर से/Respondent By : Shri Nitin Kulkarni, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 26/08/2025 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), (Hereinafter Referred To As “Cit(A)”), National Faceless Appeal Centre (Hereinafter Referred To As “Nfac”), Delhi Dated 21.02.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As The “Act”) & Relates To Assessment Year (A.Y.) 2012-13. 2. The Grounds Raised In The Appeal By The Assessee Are As Under:

For Appellant: Shri M K Patel, AdvocateFor Respondent: Shri Nitin Kulkarni, Sr. DR

Section 250Section 69A

assessee amounting to Rs.9,23,000/-, the source of which, remained unexplained. The addition was made to the income of the assessee as unexplained money / cash deposited in Bank u/s.69A of the Act, in the absence of any evidence filed by the assessee before the AO substantiating the source