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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

Architecture and Engineering Consultancy Services Private Limited, Bhubaneswar vs. Deputy Commissioner of Income Tax, Central Circle-2 Bhuabenswar, Bhubaneswar

In the result, all the five appeals of the assessee are allowed

ITA 343/CTK/2025[2014-15]Status: DisposedITAT Cuttack01 Dec 2025AY 2014-15

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.340, 342, 343, 344 & 345/Ctk/2025 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17) Architecture & Engineering Vs Dcit, Central Circle-2, Consultancy Services Pvt. Ltd., Bhubaneswar Plot No.3443, Palasuni, Rasulgarh Bhubaneswar-751010 Pan No. :Aafca 8879 F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri K.C.Jena & Shri Mohit Sheth, Ars राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/12/2025 घोषणा की तारीख/Date Of Pronouncement : 01/12/2025 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar, All Dated 31.03.2025 For The Assessment Years 2012-2013, 2013-2014, 2014-2015, 2015-2016 & 2016-2017, Respectively. 2. All The Five Appeals Of The Assessee Is Barred By 04 Days Each. In This Regard, The Assessee Has Filed Condonation Application Supported With An Affidavit Stating Therein Sufficient Reasons For Condonation Of Delay. Ld.Sr. Dr Also Did Not Object To The Same. Accordingly, We Condone The Delay Of 04 Days Each In Said Appeals & Proceed To Dispose Off All The Appeals Of The Assessee Under Consideration.

For Appellant: Shri K.C.Jena & Shri Mohit Sheth, ArsFor Respondent: Shri Vijay Singh, Sr. DR
Section 143(1)

allegation against the assessee company that the assessee is doing any financial irregularities. There is no claim that the assessee is providing on-money transactions or share transactions. The receipts of the assessee are clearly from contracts. The receipts are through banking channels. The receipts are also from Government organizations

Architecture and Engineering Consultancy Services Private Limited, Bhubaneswar vs. Deputy Commissioner of Income Tax, Central Circle-2 Bhubaneswar, Bhubaneswar

In the result, all the five appeals of the assessee are allowed

ITA 342/CTK/2025[2013-14]Status: DisposedITAT Cuttack01 Dec 2025AY 2013-14

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.340, 342, 343, 344 & 345/Ctk/2025 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17) Architecture & Engineering Vs Dcit, Central Circle-2, Consultancy Services Pvt. Ltd., Bhubaneswar Plot No.3443, Palasuni, Rasulgarh Bhubaneswar-751010 Pan No. :Aafca 8879 F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri K.C.Jena & Shri Mohit Sheth, Ars राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/12/2025 घोषणा की तारीख/Date Of Pronouncement : 01/12/2025 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar, All Dated 31.03.2025 For The Assessment Years 2012-2013, 2013-2014, 2014-2015, 2015-2016 & 2016-2017, Respectively. 2. All The Five Appeals Of The Assessee Is Barred By 04 Days Each. In This Regard, The Assessee Has Filed Condonation Application Supported With An Affidavit Stating Therein Sufficient Reasons For Condonation Of Delay. Ld.Sr. Dr Also Did Not Object To The Same. Accordingly, We Condone The Delay Of 04 Days Each In Said Appeals & Proceed To Dispose Off All The Appeals Of The Assessee Under Consideration.

For Appellant: Shri K.C.Jena & Shri Mohit Sheth, ArsFor Respondent: Shri Vijay Singh, Sr. DR
Section 143(1)

allegation against the assessee company that the assessee is doing any financial irregularities. There is no claim that the assessee is providing on-money transactions or share transactions. The receipts of the assessee are clearly from contracts. The receipts are through banking channels. The receipts are also from Government organizations

Architecture and Engineering Consultancy Services Private Limited, Bhubaneswar vs. Deputy Commissioner of Income Tax, Central Circle-2 Bhubaneswar, Bhubaneswar

In the result, all the five appeals of the assessee are allowed

ITA 340/CTK/2025[2012-13]Status: DisposedITAT Cuttack01 Dec 2025AY 2012-13

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.340, 342, 343, 344 & 345/Ctk/2025 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17) Architecture & Engineering Vs Dcit, Central Circle-2, Consultancy Services Pvt. Ltd., Bhubaneswar Plot No.3443, Palasuni, Rasulgarh Bhubaneswar-751010 Pan No. :Aafca 8879 F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri K.C.Jena & Shri Mohit Sheth, Ars राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/12/2025 घोषणा की तारीख/Date Of Pronouncement : 01/12/2025 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar, All Dated 31.03.2025 For The Assessment Years 2012-2013, 2013-2014, 2014-2015, 2015-2016 & 2016-2017, Respectively. 2. All The Five Appeals Of The Assessee Is Barred By 04 Days Each. In This Regard, The Assessee Has Filed Condonation Application Supported With An Affidavit Stating Therein Sufficient Reasons For Condonation Of Delay. Ld.Sr. Dr Also Did Not Object To The Same. Accordingly, We Condone The Delay Of 04 Days Each In Said Appeals & Proceed To Dispose Off All The Appeals Of The Assessee Under Consideration.

For Appellant: Shri K.C.Jena & Shri Mohit Sheth, ArsFor Respondent: Shri Vijay Singh, Sr. DR
Section 143(1)

allegation against the assessee company that the assessee is doing any financial irregularities. There is no claim that the assessee is providing on-money transactions or share transactions. The receipts of the assessee are clearly from contracts. The receipts are through banking channels. The receipts are also from Government organizations