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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

Deputy Commissioner of Income Tax, Chennai vs. Singhvi Developers, Vellore

In the result, both appeals of Revenue and the assessee are dismissed

ITA 974/CHNY/2025[2019-20]Status: DisposedITAT Chennai24 Feb 2026AY 2019-20

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.648/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 M/S. Singhvi Developers, Vs. The Deputy Commissioner Of No. 5/3, Kasi Chetty Street, Income Tax, Ambur 635 803. Central Circle 3(3), Chennai. [Pan:Acdfs5183R] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.974/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 The Deputy Commissioner Of Vs. M/S. Singhvi Developers, Income Tax, No. 5/3, Kasi Chetty Street, Central Circle 3(3), Ambur 635 803. Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri D. Anand, Advocate ""थ" की ओर से/Department By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 13.01.2026 घोषणा की तारीख /Date Of Pronouncement 24.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The Order Dated 20.12.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) 20, Chennai For The Assessment Year 2019-20. 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 143(3)

appellant. On the basis of the findings as above, it can be concluded that the appellant is involved in receipt and payment of on-money which was utilized in the transactions related to immovable properties over a period of years and the excess unutilized cash is deposited in the bank

Singhvi Developers, Ambur vs. DCIT Central Circle 3(3), Chennai

In the result, both appeals of Revenue and the assessee are dismissed

ITA 648/CHNY/2025[2019-20]Status: DisposedITAT Chennai24 Feb 2026AY 2019-20

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.648/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 M/S. Singhvi Developers, Vs. The Deputy Commissioner Of No. 5/3, Kasi Chetty Street, Income Tax, Ambur 635 803. Central Circle 3(3), Chennai. [Pan:Acdfs5183R] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.974/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 The Deputy Commissioner Of Vs. M/S. Singhvi Developers, Income Tax, No. 5/3, Kasi Chetty Street, Central Circle 3(3), Ambur 635 803. Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri D. Anand, Advocate ""थ" की ओर से/Department By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 13.01.2026 घोषणा की तारीख /Date Of Pronouncement 24.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The Order Dated 20.12.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) 20, Chennai For The Assessment Year 2019-20. 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 143(3)

appellant. On the basis of the findings as above, it can be concluded that the appellant is involved in receipt and payment of on-money which was utilized in the transactions related to immovable properties over a period of years and the excess unutilized cash is deposited in the bank