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“on-money”

Cash Credits & Unexplained ItemsSection 69BSection 69B1,574 judgments

The decision most relied on for on-money is CIT v. President Industries (258 ITR 654), cited in 471 judgments on BharatTax.

Leading authorities on on-money

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

CIT v. Girish Chaudhary
296 ITR 619 · 2008 · High Court
175
citing judgments

Additions to income cannot be made solely based on "dumb documents" or vague loose papers seized during a search that merely indicate rates without specific corroborative material linking them to the assessee's unaccounted transactions. The presumption under Section 292C may not apply to such documents.

Principal Commissioner Income Tax, Central-2 v. Umesh Ishrani
108 Taxmann.com 437 · 2019 · High Court
168
citing judgments

An addition to income cannot be made solely based on entries in loose papers found during a search without conducting any independent inquiry or verification from the alleged seller or developer. Reliance solely on digital records without corroborative evidence is insufficient for an addition.

CIT v. Maulikkumar K. Shah
307 ITR 137 · 2008 · High Court
166
citing judgments

Additions on account of on-money receipts cannot be justified solely based on loose papers or 'sauda-chithis' without evidence of actual payment or a clear indication of a completed transaction within those documents.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

CIT v. Shivakami Co. (P.) Ltd.
159 ITR 71 · 1986 · Supreme Court
133
citing judgments

The burden of proving an understatement of consideration or the receipt of 'on-money' lies solely with the Revenue, which must provide cogent evidence of actual receipt of higher consideration, beyond mere estimates or suspicion. Additions cannot be made based on assumptions like differences from circle rates without such evidence.

Man Mohan Sadani v. CIT
304 ITR 52 · 2008 · High Court
132
citing judgments

When assessing income from undisclosed or unrecorded sales, the entire sale proceeds cannot be added to the assessee's income; instead, only the net profit embedded in such unaccounted sales, determined by applying the assessee's net profit rate, should be taxed.

Judgments citing on-money

Gaurav Gupta, Dehradun vs. DCIT, Dehradun

Appeal is allowed

ITA 132/DDN/2025[2019-20]Status: DisposedITAT Dehradun18 Feb 2026AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 132/Ddn/2025 : Asstt. Year: 2019-20 Gaurav Gupta, Vs Dcit, 79, Saraswati Soni Marg, Laxman Central Circle, Chowk, Dehradun-248001 Dehradun-248001 (Appellant) (Respondent) Pan No. Alapg9829Q Assessee By : Sh. Subhash Gupta, Ca Revenue By : Sh. Amar Pal Singh, Sr. Dr Date Of Hearing: 16.01.2026 Date Of Pronouncement: 18.02.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2019-20, Arises Against The Cit(A)-3, Noida’S Din & Order No. Itba/Apl/M/250/2025-26/1076715221(1) Dated 04.06.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

For Appellant: Sh. Subhash Gupta, CAFor Respondent: Sh. Amar Pal Singh, Sr. DR
Section 147

course of hearing that the assessee raises his sole substantive grievance directed against both the learned lower authorities’ assessment and lower appellate findings making on-money payment addition of Rs.12,50,000/- in his hands. 2 Gaurav Gupta 4. The Revenue vehemently argues in this factual backdrop that the impugned ... assessee’s and his brother’s name which form subject matter of adjudication. The same nowhere even remotely indicates that the impugned alleged on-money stood paid at anytime which is a clear cut instance of the same lacking the due corroboration thereof at the Revenue’s behest. We thus

Mrs. Dhoomi Devi, Chamoli vs. ITO, W-1(4)4, Srinagar, Chamoli

In the result, appeal of the assessee is partly allowed

ITA 149/DDN/2024[2022-23]Status: DisposedITAT Dehradun13 Feb 2026AY 2022-23

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2022-23] Mrs. Dhoomi Devi Vs Ito C/O-Hotel Udai Palace Near . Ward-1(4)4 Narsingh Temple Srignagar, Chamoli Joshimath Chamoli, Uttarakhand-246174 Uttarakhand-246443 Pan-Adkpd6984B Appellant Respondent Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10329482 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 05.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & The Case Was Selected For Scrutiny Under Cass For Reason I.E. “Large Investment In Immovable Property As Compared To The Total Income”. The Ao Than Passed The Assessment Order U/S 143(3) R.W.S. 144B On 05.03.2024 At A Total Income Of Inr 2,70,31,224/- As Against The Total Income Declared At Inr 29,45,000/- In The Return Of Income Filed By The Assessee.

Section 143(3)Section 250Section 54FSection 54F(1)

erred in upholding an addition to Total Income of Rs 50,00,000/- on account of alleged "on-money" for purchase of property. 6. That on facts and in law the CIT(A) has erred in upholding that seizure of cash and other documents by the FST team ... raised by the assessee are with respect to the addition of INR 50 Lakhs made by holding that the same as unexplained on-money paid in cash for the acquisition of the new property. 12. Facts of the issue are that on 19.01.2022 during the State Assembly election, one person