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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

Vishal Ramesh Fegade, Aurangabad vs. Assessing Officer, Ward 1(5), Aurangabad

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

ITA 2503/PUN/2025[2020-21]Status: DisposedITAT Pune22 Jan 2026AY 2020-21

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2503/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Vishal Ramesh Fegade, Vs. Ito, Ward- 1(5), A-B-8, Tapadia Pride, Aurangabad. Paithan Road, Aurangabad- 431001. Pan : Aanpf6699K Appellant Respondent Assessee By : Shri Anup Shaha Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing : 14.01.2026 Date Of Pronouncement : 22.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 27.08.2025 Which Is Arising Out Of The Assessment Order U/S 147 Of The Act For Assessment Year 2020-21 Framed On 17.03.2013 By The Ito, Ward-1(5), Aurangabad. 2. The Assessee Has Raised Following Grounds Of Appeal :- “1. I, Vishal Ramesh Fegade, Am A Salaried Employee & My Primary Source Of Income Is Derived Solely From My Employment. I Would Like To Explicitly State That I Have Not Made Any Cash Payments In Relation To The Purchase Of The Property In Question. All Payments Made Towards The Acquisition Of The Property Have Been Conducted Through Formal Banking Channels, Ensuring Full Transparency & Compliance With Legal Requirements. The Details Of These Payments Are Clearly Outlined In The Purchase Deed.

For Appellant: Shri Anup ShahaFor Respondent: Shri Shashank Ojha (Virtual)
Section 132Section 143(2)Section 147Section 148Section 151ASection 69

remaining grounds are concerned, the grievance of the assessee are against the addition of Rs.7,50,000/- made by the Assessing Officer for on-money payment made for purchase of immovable property. 5. Brief facts of the case are that the assessee is an individual. Ld. Assessing Officer based ... Employee of Gadiya Group and also referred to certain incriminating material in the form of receipts for the cash received from the assessee towards on-money amounting to Rs.7,50,000/-. Since the assessee was unable to explain the source of alleged cash payment, Ld. Assessing Officer concluded the proceedings