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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

Abhay Hargovindbhai Patel, Jamnagar vs. The Income Tax Officer, Jamnagar

In the result, the appeal filed by the assessee is partly allowed, in above terms

ITA 17/RJT/2024[2017-18]Status: DisposedITAT Rajkot16 Jul 2025AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपीलसं./Ita No. 17/Rjt/2024 निर्धारणवर्ष / Assessment Year: (2017-18) (Hybrid Hearing) Abhay Hargovindbhai Patel Vs. The Income Tax Officer, Ward 305, Dwarkeshdham,B/H. Samudra 1(3), Jamnagar Sales, Rajnagar, Aerodram Road, 1St Floor, Taranjali Building, Pn Jamnagar 361006 Marg, Aubpp7196D Jamnagar 361008 (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. (Dr) Date Of Hearing : 27/04/2025 Date Of Pronouncement : 16/07/2025 आदेश / Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By Commissioner Of Income Tax (Appeals), Vide Order Dated 08/11/2023, Which In Turn Arises Out Of An Order Passed By The Assessing Officer, Dated 26/11/2019, U/S 144 Of The Income Tax Act, 1961. Page 1

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri K. L. Solanki, Ld. Sr. (DR)
Section 120(5)Section 133(6)Section 139Section 142(1)Section 144Section 69A

rate is appropriate in case of “on money”. Therefore, we are of the view that treating the cash deposit of the assessee, as an “on-money”, of the assessee, we confirm the addition of 30% of the total cash deposited in the bank account. Therefore, we direct the assessing officer