← All Phrases

“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

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Manu Gupta, Dhuri

The appeal stand dismissed

ITA 202/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh10 Nov 2025AY 2022-23

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.201/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit Shri Rohit Gupta बनाम/ Central Circle-1 C/O Gupta Textile Trading Co. Vs. Ludhiana Old Anaj Mandi, Dhuri, Punjab-148024 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Acapg-4615-M (अपीलाथ"/Appellant) : (""थ" / Respondent) 2. आयकर अपील सं./ Ita No.202/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit Shri Manu Gupta बनाम/ Central Circle-1 C/O Gupta Textile Trading Co. Vs. Ludhiana Old Anaj Mandi, Dhuri, Punjab-148024 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Acapg-4616-J (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Sudhir Sehgal (Advocate) – Ld. Ar Revenue By : Shri Abhishek Pal Garg (Cit) -Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 28-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Facts In Captioned Twin Appeals For Assessment Year (Ay) 2022-23 Are Admittedly Identical. First, We Take Up Revenue’S Appeal Ita No. 201/Chandi/2025 Which Arises Out Of An Order Of Learned

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Shri Abhishek Pal Garg (CIT) -Ld. DR (Virtual)
Section 132Section 143(3)Section 69B

cases on 16-11-2021, the impugned assessment was framed. During search, various incriminating material were found and seized which indicated payment of on-money by the purchasers to HBPL. The assessee acted as one of the directors of HBPL. M/s HBPL is stated to be engaged in real estate ... residential plots was determined at Rs.33,000/- per square Yards. Accordingly, the assessee was show-caused wherein Ld. AO proposed addition of alleged on-money. The assessee, vide its reply dated 15-03-2024, refuted the allegation of Ld. AO which did not find favor with Ld. AO. Going

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rohit Gupta, Dhuri

The appeal stand dismissed

ITA 201/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh10 Nov 2025AY 2022-23

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.201/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit Shri Rohit Gupta बनाम/ Central Circle-1 C/O Gupta Textile Trading Co. Vs. Ludhiana Old Anaj Mandi, Dhuri, Punjab-148024 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Acapg-4615-M (अपीलाथ"/Appellant) : (""थ" / Respondent) 2. आयकर अपील सं./ Ita No.202/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit Shri Manu Gupta बनाम/ Central Circle-1 C/O Gupta Textile Trading Co. Vs. Ludhiana Old Anaj Mandi, Dhuri, Punjab-148024 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Acapg-4616-J (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Sudhir Sehgal (Advocate) – Ld. Ar Revenue By : Shri Abhishek Pal Garg (Cit) -Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 28-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Facts In Captioned Twin Appeals For Assessment Year (Ay) 2022-23 Are Admittedly Identical. First, We Take Up Revenue’S Appeal Ita No. 201/Chandi/2025 Which Arises Out Of An Order Of Learned

For Appellant: Shri Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Shri Abhishek Pal Garg (CIT) -Ld. DR (Virtual)
Section 132Section 143(3)Section 69B

cases on 16-11-2021, the impugned assessment was framed. During search, various incriminating material were found and seized which indicated payment of on-money by the purchasers to HBPL. The assessee acted as one of the directors of HBPL. M/s HBPL is stated to be engaged in real estate ... residential plots was determined at Rs.33,000/- per square Yards. Accordingly, the assessee was show-caused wherein Ld. AO proposed addition of alleged on-money. The assessee, vide its reply dated 15-03-2024, refuted the allegation of Ld. AO which did not find favor with Ld. AO. Going

Ratnadeep Infrastructure Private Limited, Ahmedabad vs. Income Tax Officer, Old Ward 3(1)(3), New Ward 3(1)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1491/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.1490/Ahd/2025, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.1491/Ahd/2025, Asst.Year 2012-13 Ratnadeep Infrastructure The Income Tax Officer बनाम/ Private Limited Old Ward-3(1)(3) V/S. 126, 1St Floor New 3 (1) (2) Neelam Shopping Center Krishna Nagar Chowk Ahmedabad – 382 346 "थायी लेखा सं./Pan: Aaecr 5728 F (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri Abhijit, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Of Even Date 01/07/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2011-2012 & 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.1490/Ahd/2025 For Ay 2011-12:

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Abhijit, Sr.DR
Section 131Section 143(1)Section 143(3)Section 147Section 250Section 271(1)(c)Section 69

cash component, for taxation. This admission by the seller, according to the CIT(A), served as strong corroboration of the AO’s findings that on-money was indeed paid by the assessee. The CIT(A) further emphasized that under section 69 of the Act read with Explanation 1, the burden