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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

Ganadhish Gnp, Navi Mumbai vs. DCIT Circle 6(1), Mumbai

In the result, all the appeals filed by the assessee are partly allowed and all the appeals filed by the Revenue are dismissed

ITA 3966/MUM/2024[2019-20]Status: DisposedITAT Mumbai17 Mar 2025AY 2019-20

Bench: Shri Amarjit Singh, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Bleita No. 3965/Mum/2024 (A.Y. 2020-21) Ganadhish Gnp Dcit, Circle-6(1), Mumbai Shop No. 1203, 12Th Floor, Rupa Solitaire, Building No. A-I, Vs Sector-I, Millennium Business Park, Mahape Navi Mumbai- 400710. Pan: Aapfg 1164 L (Appellant) (Respondent) Ita No. 4481/Mum/2024 (A.Y. 2021-22) Dcit, Circle-6(1), Ganadhish Gnp Mumbai Shop No. 1203, 12Th Floor, Rupa Solitaire, Building No. A- Vs I, Sector-I, Millennium Business Park, Mahape Navi Mumbai-400710. Pan: Aapfg 1164 L (Appellant) (Respondent)

For Appellant: Shri Nishit Gandhi & Aadnya BhandariFor Respondent: Dr. Kishor Dhule, CIT/DR
Section 132Section 132(4)

group cases and at the offices of GNP Group at Nariman Point, Mumbai on 23.09.2021. During the search incriminating evidences in the form of “On-Money” sheets were found pertaining to the assessee M/s. Ganadhish GNP. The assessee firm constructed a commercial complex at ITA Nos. 4481 & 4485/Mum/2024 M/s. Ganadhish ... name of “GNP Galleria”. During the course of search action at the office premises of the GNP Group incriminating evidences in the form of “On-Money” sheets found as per which various commercial units were sold on which “On- Money” was received as per the detail of the sheet dated

Shreya Santosh Kadam, Mumbai vs. Income Tax Officer 34(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 227/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Mar 2025AY 2015-16

Bench: Shri B.R. Baskaran & Shri Sandeep Gosainassessment Year : 2015-16 Shreya Santosh Kadam, Income Tax Officer-34(3)(1), D 1302, Sanskar, Kautilya Bhavan, Neelam Nagar, Vs. Bandra Kurla Complex, Mulund East, Bandra East, Mumbai-400 081. Mumbai-400 051. Pan :Beqpk9770N (Appellant) (Respondent) Assessee By : Shri Dharan Gandhi Revenue By : Shri Kiran Unavekar, Sr.Dr Date Of Hearing : 12-03-2025 Date Of Pronouncement : 17-03-2025 Order Per B.R. Baskaran, A.M : The Assessee Has Filed This Appeal Challenging The Order Dt.17-11-2023 Passed By The Ld. Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟] & It Relates To Ay. 2015-16. The Assessee Is Aggrieved By The Decision Rendered By The Ld.Cit(A) In Confirming The Addition Of Rs.33,72,590/- Relating To Alleged On-Money Payment Made By The Assessee.

For Appellant: Shri Dharan GandhiFor Respondent: Shri Kiran Unavekar, Sr.DR
Section 132(4)Section 148Section 69Section 69C

assessee is aggrieved by the decision rendered by the Ld.CIT(A) in confirming the addition of Rs.33,72,590/- relating to alleged on-money payment made by the assessee. 2. The assessee had purchased a flat from Runwal Group. A search action u/s. 132(4) of the Income ... conducted in the hands of Runwal Group; wherein they had admitted that they have received on-money by way of cash. It was noticed that a sum of Rs.33,72,590/- was found noted against the name of the assessee. Based on the statement given by the Runwal Group