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“undisclosed income”

Search & SeizureSection 153ASection 153A9,092 judgments

The decision most relied on for undisclosed income is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on undisclosed income

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

Commissioner of Income Tax v. Harjeev Aggarwal
290 CTR 263 · 2016 · High Court
583
citing judgments

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

CIT v. Anil Kumar Bhatia
352 ITR 493 · 2013 · High Court
537
citing judgments

Section 153A can be invoked to reassess income for all years under consideration prior to a search, even if returns for those years were processed under Section 143(1)(a). The Assessing Officer has the power to reassess total income in such cases without fetters.

CIT v. P. Mohanakala
291 ITR 278 · 2007 · Supreme Court
525
citing judgments

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

Society v. UOI
394 ITR 220 · 2017 · Supreme Court
493
citing judgments

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

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. Gurinder Singh Bawa
386 ITR 483 · 2016 · High Court
416
citing judgments

If no incriminating material is found during a search operation regarding a particular issue, then no addition can be made concerning that issue in an assessment under section 153A of the Income-tax Act.

Judgments citing undisclosed income

Kuldeep Saluja, Delhi vs. DCIT, Central Circle-6, New Delhi

ITA 2460/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Feb 2026AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 139Section 142(1)Section 143(2)Section 143(3)Section 153CSection 153DSection 250Section 68

ITA No.2460/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "B" BENCH: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER & SHRI

Vinay Homes Pvt Ltd, Delhi vs. DCIT, Central Circle-6, New Delhi

ITA 2459/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 139Section 142(1)Section 143(2)Section 153CSection 153DSection 250Section 68Section 69C

ITA No.2459/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "B" BENCH: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER & SHRI

Yogesh Chadha, New Delhi vs. ITO, Ward- 31(2), Delhi

In the result, the appeal of the assessee, is allowed for statistical purposes

ITA 1498/DEL/2025[2010-11]Status: DisposedITAT Delhi06 Feb 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2010-11]

Section 144Section 148Section 234ASection 234BSection 234CSection 250

year on surmises and presumptions without collecting proper information. 4. The learned AO has erred in making an addition of Rs. 282782/- as undisclosed income on the basis of statement statement but not granting credit for the TDS appearing in the same statement. 5. The learned AO has erred ... making an addition of Rs 250000 of Commission Credit as undisclosed income without allowing any expenses 4. During the course of appellate proceedings, notices u/s.250 of the Act were issued on various dates. The appellant has filed the submissions.” 4. It was argued that it had raised legal grounds before

Income Tax Officer, Aaykar Bhawan vs. Shiv Shankar Rice Mills, Gogripur Road

In the result, the appeal of the Revenue is dismissed

ITA 4630/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2013-14]

Section 143(3)Section 147Section 148Section 151

appellant have not been doubted and has already been taken in the P&L A/c of the appellant, the same cannot be added as undisclosed income u/s 68 of the Act. Hence, I find force in the contention of the appellant that the sale

DCIT, New Delhi vs. Prudential Hotels Pvt. Ltd., Delhi

In the result both the grounds raised by the revenue are dismissed

ITA 2936/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 143(2)

during the year to the extent of Rs. 7,70,00,000/- (as mentioned supra) whose creditworthiness have not been proved, is treated as undisclosed income of the assessee in view of the above mentioned facts and discussion and hence the same is added to the income of the assessee

Sachin, Delhi vs. ACIT, Central Circle-20, New Delhi

In the result, the assessee’s appeal stand dismissed

ITA 1678/DEL/2023[2019-20]Status: DisposedITAT Delhi06 Feb 2026AY 2019-20

Bench: Shri Mahavir Singh & Shri Krinwant Sahaysachin, Vs. Acit, Cc-20, House No. 28R, Gali No. 6A, New Delhi Swatantra Nagar, Narela, New Delhi – 110 044 (Pan:Dlrps3290H) (Appellant) (Respondent) Appellant By : Shri Varun Gupta, Ca Respondent By : Shri Mahesh Kumar, Cit(Dr)

For Appellant: Shri Varun Gupta, CAFor Respondent: Shri Mahesh Kumar, CIT(DR)
Section 143(3)Section 153ASection 69A

sales, debtors, funds received from relatives was deposited in locker of the assessee as the cash was received from his own sources not from undisclosed income. During the relevant financial year total cash of Rs. 26,50,000/- was deposited in the locker no. 108, Faquir Chand Lockers and Vaults

ACIT, Central Circle-2, Patna vs. Shri Nagendra Prasad, Patna

In the result, appeal of the revenue stands allowed

ITA 109/PAT/2020[2010-11]Status: DisposedITAT Patna05 Feb 2026AY 2010-11

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: Shri N.K.Lal, FCAFor Respondent: Md. A.H.Chowdhary, CIT-DR
Section 143(3)Section 147

Ld.CIT(A) for giving relief to the assessee. It was also the submission that amounts deposited in the bank doesn’t automatically become undisclosed income. It was submission that these amounts were relating to the earlier years and the same were liable to be taxed only in the years ... Bank Of Baroda, Buxar Branch has also been recorded. When such substantial evidence is available, insofar as the assessee admits that it is an undisclosed income of the assessee, the assessee’s son admits that the money is belonged to his father and it is for the father to explain

DCIT, Central Circle-4(3), Kolkata vs. Raj Goenka, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1801/KOL/2025[2022-23]Status: DisposedITAT Kolkata05 Feb 2026AY 2022-23

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2022-23 Dcit, Cc-4(3), Kolkata……...……..……….………….……….……….……Appellant Vs. Raj Goenka…………………………………………..…….....……...…..…..Respondent 10Th Floor Magma House, 24, Park Street Park Street, Kol-16. [Pan: Adlpg8181C] Appearances By: Shri S B Chakraborthy, Addl. Cit, Appeared On Behalf Of The Appellant. Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : February 05, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 12.04.2025 Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2022–23. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 08 Days. The Revenue Has Filed A Petition For Condonation Of The Delay. After Considering The Reasons Cited In The Petition For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 127Section 132(1)Section 139Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

reject it. On the other hand, if the explanation is unconvincing, the same can be rejected and an inference shows that the amount represents undisclosed income either from a disclosed or an undisclosed source. The explanation given by the assessee cannot be rejected arbitrarily or capriciously, without sufficient ground

M/S. Khemka Stuart Leisure Ltd., New Delhi vs. ACIT, New Delhi

The appeal is dismissed

ITA 2360/DEL/2015[2005-06]Status: DisposedITAT Delhi05 Feb 2026AY 2005-06

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandraita No. 2360/Del/2015 : Asstt. Year: 2005-06 M/S Khemka Stuart Leisure Ltd., Vs Acit, B-8, Basement Floor, Ansal Tower, Central Circle-18, 38, Nehru Place, New Delhi-110019 New Delhi (Appellant) (Respondent) Pan No. Aaack4630P Assessee By : Sh. Rajeshwar Painuly, Adv. Revenue By : Ms. Monika Singh, Cit-Dr Date Of Hearing: 05.02.2026 Date Of Pronouncement: 05.02.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2005-06 Arises Against The Cit(A)-Xxvii, New Delhi’S Dated 27.11.2014, In Case No. 407/13-14/Cit(A)-Xxvii/2014-15, In Proceedings U/S 143(3)/147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rajeshwar Painuly, AdvFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 139(1)Section 143(2)Section 143(3)Section 148

well as in the lower appellate discussion inter 2 Khemka Stuart Leisure Ltd. alia initiating section 148 proceedings culminating in the addition of undisclosed income of Rs.3,84,86,000/- in question. 4. Learned CIT(A)’s lower appellate discussion appears to have upheld the assessment findings to this effect ... dated 19.12.2007 is being assessed u/s 143(3)/147 of the Income Tax Act, 1961. The amount of undisclosed income of Rs.3,84,86,000/- will be taxed in the year when the project was completed." 3. In response to the notice issued

Mukesh Agarwal, Rourkela vs. Income Tax Office, Ward 1, Rourkela

Appeal of the assessee is allowed

ITA 631/CTK/2025[2015-16]Status: DisposedITAT Cuttack04 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuआयकर अपील सं/Ita No.631/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2015-2016) Mukesh Agarwal, Vs Ito Ward-1, Rourkela O-18, Civil Township, Rourkela-769004 Pan No. : Adipa 0575 D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Ayush Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 04/02/2026 घोषणा की तारीख/Date Of Pronouncement : 04/02/2026 आदेश / O R D E R Per George Mathan, Jm :

For Appellant: Shri Ayush Agarwal, ARFor Respondent: Shri Vijay Singh, Sr. DR
Section 10(38)

cases to this effect. Hence we hold that the ld AO was not justified in assessing the sale proceeds of shares of KAFL as undisclosed income of the assessee u/s 68 of the Act. We accordingly hold that the reframed question no. 1 raised hereinabove is decided in the negative

Puja Agarwal, Rourkela vs. ITO Ward 1, Rourkela

Appeal of the assessee is allowed

ITA 628/CTK/2025[2015-16]Status: DisposedITAT Cuttack04 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuआयकर अपील सं/Ita No.628/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2015-2016) Puja Agarwal, Vs Ito Ward-1, Rourkela O-18, Civil Township, Rourkela-769004 Pan No. : Agwpa 5744 K (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Ayush Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 04/02/2026 घोषणा की तारीख/Date Of Pronouncement : 04/02/2026 आदेश / O R D E R Per George Mathan, Jm :

For Appellant: Shri Ayush Agarwal, ARFor Respondent: Shri Vijay Singh, Sr. DR
Section 10(38)

cases to this effect. Hence we hold that the ld AO was not justified in assessing the sale proceeds of shares of KAFL as undisclosed income of the assessee u/s 68 of the Act. We accordingly hold that the reframed question no. 1 raised hereinabove is decided in the negative

Harsh Deep Burman, Nawada vs. Ac/Dc, Ac/Dc Circle Two

In the result, appeal of the assessee is dismissed

ITA 501/PAT/2025[2016-17]Status: DisposedITAT Patna04 Feb 2026AY 2016-17

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: Shri Vimlesh Kumar, AdvFor Respondent: Sh. Manab Adak, JCIT
Section 133Section 133ASection 139(1)Section 143(2)Section 250Section 69

cause notice was also issued to the assessee dated 19.11.2018. During the course of survey proceedings, the assessee admitted Rs. 25,00,000/- as undisclosed income towards investment in land and building and during the course of assessment proceedings the assessee made submissions regarding investment in land and building that ... their respective bank account. During the course of deposition, Mr. Harshdeep Burman simply accepted that the money advance for the land is actual his undisclosed income. The judicial pronouncement held by the Hon’ble High Court as the case of Hira Singh

Rajeshbhai Parsottamdas Patel, Vadodara vs. The ITO, Ward-4(1)(2), Vadodara

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 429/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad04 Feb 2026AY 2017-18

Bench: Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Sanket Bakshi, A.RFor Respondent: Shri Rameshwar P. Meena, Sr. D.R
Section 143(2)Section 234BSection 271ASection 69A

Income Tax Officer, Ward-4(1)(2) ("the AO"), Baroda erred in fact and in law in considering deposit of Rs.12,50,000/- as undisclosed income and making addition of the same. 2. The learned CIT(A) and the learned AO erred in fact and in law in computing ... during the demonetization period in his bank account. The Assessing Officer made addition of 12,50,000/- u/s. 69A on account of undisclosed income. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee

K V Tex Firm, Chennai vs. Asst. Commissioner of Income Tax, Chennai

Appeals of the assessee stand allowed

ITA 1865/CHNY/2025[2022-23]Status: DisposedITAT Chennai04 Feb 2026AY 2022-23

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 132Section 139(1)Section 143Section 147Section 44A

trading account stood recorded and unaltered in the system. On that basis, the Assessing Officer concluded that the entire difference in sales constituted undisclosed income u/s.69A of the Act, and not merely the gross profit component thereof. 12. Based on the above reasoning, the AO made addition to the returned ... Rs.6,89,90,818 2022-23 Rs.3,71,66,199 TOTAL Rs.17,25,23,775 13. The AO further held that the undisclosed income so determined was liable to be taxed u/s.115BBE r.w.s.69A of the Act, on the footing that the said income represented unaccounted income allegedly unearthed pursuant

K V Tex Firm, Chennai vs. Asst. Commissioner of Income Tax, Chennai

In the result, all the three appeals of the assessee stand allowed

ITA 1860/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Feb 2026AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 132Section 139(1)Section 143Section 147Section 44A

trading account stood recorded and unaltered in the system. On that basis, the Assessing Officer concluded that the entire difference in sales constituted undisclosed income u/s.69A of the Act, and not merely the gross profit component thereof. 12. Based on the above reasoning, the AO made addition to the returned ... Rs.6,89,90,818 2022-23 Rs.3,71,66,199 TOTAL Rs.17,25,23,775 13. The AO further held that the undisclosed income so determined was liable to be taxed u/s.115BBE r.w.s.69A of the Act, on the footing that the said income represented unaccounted income allegedly unearthed pursuant

K V Tex Firm, Chennai vs. Asst. Commissioner of Income Tax, Chennai

Appeals of the assessee stand allowed

ITA 1859/CHNY/2025[2021-22]Status: DisposedITAT Chennai04 Feb 2026AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 132Section 139(1)Section 143Section 147Section 44A

trading account stood recorded and unaltered in the system. On that basis, the Assessing Officer concluded that the entire difference in sales constituted undisclosed income u/s.69A of the Act, and not merely the gross profit component thereof. 12. Based on the above reasoning, the AO made addition to the returned ... Rs.6,89,90,818 2022-23 Rs.3,71,66,199 TOTAL Rs.17,25,23,775 13. The AO further held that the undisclosed income so determined was liable to be taxed u/s.115BBE r.w.s.69A of the Act, on the footing that the said income represented unaccounted income allegedly unearthed pursuant

Assistant Commissioner of Income Tax, Chennai vs. Meenakshi Ammal Trust, Chennai

In the result, the appeal of the Revenue stands dismissed

ITA 1664/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Feb 2026AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. Shiva Srinivas, C.I.TFor Respondent: Shri. R. Venkata Raman, C.A
Section 115BSection 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 292C

Admittedly, the AO has not brought on record any independent incriminating material or cogent evidence to demonstrate that the actual undisclosed income of the assessee exceeds the aforesaid sum of Rs.29,93,61,461/-. In the absence of any such positive finding or fresh material, it cannot be presumed that

Krishan Kumar, Gurgaon vs. Income Tax Officer, Gurgain

In the result, the appeal of the assessee is allowed

ITA 1552/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18]

Section 139(1)Section 143(3)Section 54

regard to order of ld. CIT(A) confirming the action of the Assessing Officer in treated the interest on saving bank account as undisclosed income. For this, the assessee has raised following grounds no.4, which reads as under:- “4. The Ld. AO has grossly erred in law in treating ... interest on the savings bank received by the Appellant as its undisclosed income and not granting the deduction as per the provisions of section 80TTA of the Income Tax Act, 1961.” 8. We have heard rival contentions and gone through the facts of the case. We noted that the Assessing

DCIT, Central Circle-19, New Delhi vs. Chawla Jewellers, Delhi

ITA 954/DEL/2023[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwaldcit, Vs. Chawla Jewellers Central Circle-19, 2654, Bank Street, New Delhi Karol Bagh, Central Delhi Delhi-110005

For Appellant: Sh. I.P. Bansal, Adv&For Respondent: Ms. PoojaSwaroop, CIT (DR)
Section 133ASection 143(3)Section 44Section 68

assessed income of the Assessee for the financial year under consideration, then treating the cash deposited in banks against such cash sales as undisclosed income of the Assessee is not sustainable. 5. We have considered the intentions of both the sides, and we find that Ld. DR has primarily relied

DCIT, Central Circle-19, New Delhi vs. Chawla Gems Pvt. Ltd., Delhi

ITA 953/DEL/2023[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwaldcit, Vs. Chawla Gems Pvt. Ltd. Central Circle-19, 2654, Chawla Tower, New Delhi Bank Street, Karol Bagh, Central Delhi Delhi-110005

For Appellant: Sh. I.P. Bansal, Adv&For Respondent: Ms. PoojaSwaroop, CIT (DR)
Section 147oSection 148Section 44

assessed income of the Assessee for the financial year under consideration, then treating the cash deposited in banks against such cash sales as undisclosed income of the Assessee is not sustainable. 5. Ld. DR has submitted that AO has very reasonably relied the statements of employees and surrounding circumstance