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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

Kairali Bhavan Restaurant, Mangalore vs. DCIT, Central Circle-2, Mangalore, Mangaluru

ITA 1579/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Balusamy N, JCIT-DR
Section 234

survey. 29. From the assessment order, we found that the AO had merely estimated the undisclosed sales turnover and on that basis, estimated the undisclosed income. We have also considered the fact that the sale of food items could not be uniform throughout the year and the sales depends upon

Hotel Residency Park, Mangaluru vs. DCIT, Central Circle-2, Mangalore

ITA 1576/BANG/2025[2020-21]Status: DisposedITAT Bangalore12 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Balusamy N, JCIT-DR
Section 234

survey. 29. From the assessment order, we found that the AO had merely estimated the undisclosed sales turnover and on that basis, estimated the undisclosed income. We have also considered the fact that the sale of food items could not be uniform throughout the year and the sales depends upon

Hotel Malabar Regency, Mangalore vs. DCIT, Central Circle-2, Mangalore

ITA 1550/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Balusamy N, JCIT-DR
Section 234

survey. 29. From the assessment order, we found that the AO had merely estimated the undisclosed sales turnover and on that basis, estimated the undisclosed income. We have also considered the fact that the sale of food items could not be uniform throughout the year and the sales depends upon

Dalavai Audikesavulu Srinivas L/H of Late Smt D A Sathyaprabha, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 1050/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 234ASection 271(1)(c)Section 69B

assessee. (ii) Because, there is no evidence of transfer of funds from one end to another, which is a condition precedent for assessment of undisclosed income based on a seized document, as held by the Hon'ble Jurisdictional High Court and Hon'ble Supreme Court. 4. The learned AO erred

Dalavai Audikesavulu Srinivas L/H of Late Smt D A Sathyaprabha, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 1049/BANG/2025[2013-14]Status: DisposedITAT Bangalore12 Jan 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 234ASection 271(1)(c)Section 69B

assessee. (ii) Because, there is no evidence of transfer of funds from one end to another, which is a condition precedent for assessment of undisclosed income based on a seized document, as held by the Hon'ble Jurisdictional High Court and Hon'ble Supreme Court. 4. The learned AO erred

Geeta Babu Sawant, Mumbai vs. ITO 22(1)(1), Mumbai

In the result, the appeal filed by the Revenue stands

ITA 138/MUM/2026[AY 2017-18]Status: FixedITAT Mumbai12 Jan 2026

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 131Section 133(6)Section 143(3)Section 147Section 250Section 292BSection 68

balance sheet and bank statements. CBDT Circular No. F. No.286/2/2003/IT(inv) dated 11.03.2003 has directed its offices to focus on collection of evidence on undisclosed income and not on obtaining confession of undisclosed income and to make addition. (3) We The Hon'ble Supreme Court in the case ... their name are appearing in books than department is free to reopen individual assessment in accordance with law but it cannot be regarded as undisclosed income of the assessee company. The Hon'ble Bombay High Court in the case of CIT v/c Creative World Telefilms Ltd.333 ITR 100 has held

Damyanti Atul Shah, King Circle vs. Income Tax Officer Ward 20(1)(1) Mumbai, Lalbaug

In the result, the appeal is allowed for statistical

ITA 5891/MUM/2025[2013-14]Status: DisposedITAT Mumbai12 Jan 2026AY 2013-14

Bench: Shri Anikesh Banerjee

For Appellant: Shri Ryan Saldhana,ARFor Respondent: Shri Umashankar Prasad, (CIT DR)
Section 144Section 148Section 271(1)(c)

assessment order was passed u/s 144 of the Act determining the total income at Rs.1,12,82,588/- treating the above amounts as undisclosed income. Penalty u/s 271(1)(c) was also initiated for concealment of income. However, the assessee did not file any reply Page |3 ITA No. 5891/Mum/2025

Waaneep Solar Private Limited, Delhi vs. Central Circle 2(4), Mumbai

In the result, both the appeals of the assessee in ITA No

ITA 4032/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Jan 2026AY 2016-17

Bench: Justice (Retd.) C. V. Bhadang

For Respondent: Shri Arun Kanti Datta, (CIT-DR)
Section 132Section 143(3)Section 153CSection 292CSection 69C

Waaree Energies Limited has also accepted the facts and offered the amount of Rs. 8,20,40,360/- as undisclosed investment out of his undisclosed income generated out of cash eales/scrap sales/land transactions. After verifying the seized documents as stated above, I am satisfied that the belongingness with respect ... therein. Cash transactions worth Rs 8.20 cr. were mentioned therein and the MD of the company had during the search admitted the transaction as undisclosed income of the appellant company. Although the satisfaction note refers to AY 2013- 14 to 2018-19,the additions impugned before us on the basis

Waaneep Solar Private Limited, Delhi vs. Central Circle 2(4), Mumbai

ITA 4031/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Jan 2026AY 2015-16

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Shri Rushabh Mehta, ARFor Respondent: Shri Arun Kanti Datta, (CIT-DR)
Section 132Section 143(3)Section 153CSection 292CSection 69C

Waaree Energies Limited has also accepted the facts and offered the amount of Rs. 8,20,40,360/- as undisclosed investment out of his undisclosed income generated out of cash sales/scrap sales/land transactions. After verifying the seized documents as stated above, I am satisfied that the belongingness with respect ... therein. Cash transactions worth Rs 8.20 cr. were mentioned therein and the MD of the company had during the search admitted the transaction as undisclosed income of the appellant company. Although the satisfaction note refers to AY 2013- 14 to 2018-19,the additions impugned before us on the basis

Zenith Portfolio and Insurance Advisors Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Central Circle - 03, Delhi

In the result, all the appeals of the assessee are partly allowed

ITA 2508/DEL/2023[2015-16]Status: DisposedITAT Delhi12 Jan 2026AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 139(1)Section 153CSection 153D

assessment year in which information was received from the AO of the searched person. Either way, the Learned AO had not even quantified the undisclosed income as to whether it exceeds Rs 50 lakhs either individually or in the aggregate for the 7th to 10th assessment years ... have a bearing on assessee‟s income. To be more precise as to how, in satisfaction note AO concluded “During the search operation undisclosed income to the tune of Rs. 33 crores has been detected in the case of M/s Olympus Realtors (P) Ltd. resulting into concealment of income

Zenith Portfolio and Insurance Advisors Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Dentral Circle - 03, Delhi

In the result, all the appeals of the assessee are partly allowed

ITA 2507/DEL/2023[2014-15]Status: DisposedITAT Delhi12 Jan 2026AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 139(1)Section 153CSection 153D

assessment year in which information was received from the AO of the searched person. Either way, the Learned AO had not even quantified the undisclosed income as to whether it exceeds Rs 50 lakhs either individually or in the aggregate for the 7th to 10th assessment years ... have a bearing on assessee‟s income. To be more precise as to how, in satisfaction note AO concluded “During the search operation undisclosed income to the tune of Rs. 33 crores has been detected in the case of M/s Olympus Realtors (P) Ltd. resulting into concealment of income

Zenith Portfolio and Insurance Advisors Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Central Circle-03, Delhi

In the result, all the appeals of the assessee are partly allowed

ITA 2506/DEL/2023[2013-14]Status: DisposedITAT Delhi12 Jan 2026AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 132Section 139(1)Section 153CSection 153D

assessment year in which information was received from the AO of the searched person. Either way, the Learned AO had not even quantified the undisclosed income as to whether it exceeds Rs 50 lakhs either individually or in the aggregate for the 7th to 10th assessment years ... have a bearing on assessee‟s income. To be more precise as to how, in satisfaction note AO concluded “During the search operation undisclosed income to the tune of Rs. 33 crores has been detected in the case of M/s Olympus Realtors (P) Ltd. resulting into concealment of income

Rekha Gupta, Motihari vs. ACIT, Central Circle, Muzaffarpur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 81/PAT/2025[1991-92]Status: DisposedITAT Patna09 Jan 2026AY 1991-92

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.81/Pat/2025 Assessment Year: 1991-92 Rekha Gupta………..………….………………. …………………....Appellant Balua Tal, Motihari, East Champaran, Bihar-845401. [Pan: Adkpg6602P] Vs. Acit, Cc, Muzaffarpur………...……………..………………….…..... Respondent Appearances By: Shri Abhi Sarkar, Adv., Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 05, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 24.12.2024 Passed By The Nfac, Delhi U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 1991-92. 2. Brief Facts Of The Case Are That The Assessee Is An Individual Deriving Income From Business & Other Sources. During The Relevant Period, The Assessee Was Engaged In The Business Of Sale Of Liquor On Wholesale & Retail Basis In The Proprietary Concern Styled As M/S Surya Enterprises. A Search & Seizure Operation Under Section 132(1) Of The Act Was Conducted At The Business Premises As Well As The Residential Premises Of The Assessee. Pursuant Thereto, An Assessment

Section 132(1)Section 142(1)Section 158BSection 250

assessment I.T.A. No.81/Pat/2025 Rekha Gupta was framed under section 158BC of the Act for the block period from 01.04.1991 to 25.07.2000, determining total undisclosed income at ₹81,99,474. 3. Aggrieved, the assessee preferred an appeal before the Ld. CIT(A). The matter ultimately travelled to this Tribunal ... Assessing Officer made an addition of ₹24,23,499 on account of alleged undisclosed investment in stock, and an addition of ₹77,361 as undisclosed income not reflected in the return. The addition relating to stock was made on the basis of difference in trading account, allegedly derived from data

Harish Chandra Purohit, Ratlam vs. Income Tax Officer - 1, Ratlam

In the result- the Impugned order is set aside as and by way

ITA 221/IND/2025[2018-19]Status: DisposedITAT Indore09 Jan 2026AY 2018-19

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2018-19

Section 142(1)Section 147Section 148Section 148ASection 250Section 253Section 69A

documentary proof; Page 11 of 24 Harish Chandra Purohit A.Y. 2018-19 failure to do so leads to the presumption that the amount represents undisclosed income. The appellant's failure to furnish substantive proof to support his claim leaves no other conclusion but to uphold the addition made

Deepavali Balu Mahendra, Hyderabad vs. DCIT, Central Circle-2(4), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1715/HYD/2025[2023-24]Status: DisposedITAT Hyderabad09 Jan 2026AY 2023-24

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1715/Hyd/2025 Assessment Year 2023-2024 Deepavali Balu The Dcit, Vs. Mahendra, Hyderabad. Central Circle-2(4), Pin – 500 096 Telangana. Hyderabad – 500 004. Pan Adspd2577N Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca, C. Maheshwar Reddy राज" व "ारा /Revenue By: Ms Kritika Jaiswal, Sr. Ar

For Appellant: CA, C. Maheshwar ReddyFor Respondent: MS Kritika Jaiswal, Sr. AR
Section 131Section 143(3)Section 69A

considered view, without there being any contrary evidence with the Assessing Officer to allege that the cash found by the police authorities is undisclosed income of the assessee, the explanation offered by the assessee with regard to source for cash deposit needs to be accepted. Therefore, to this extent

M/S. Ramya Resorts Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

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

ITA 1938/BANG/2024[2015-16]Status: DisposedITAT Bangalore09 Jan 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: None but written submissionFor Respondent: Shri Subramanian, Jt.CIT(DR)(ITAT), Bengaluru
Section 132Section 153CSection 234ASection 269SSection 271DSection 69C

there was also a receipt of Rs.46 lakhs. Thus, after giving a set off, it was found that Rs.1,51,39,853 is the undisclosed income of the assessee. Accordingly, the ld. AO divided into 4 different years as the amount of expenditure incurred

M/S. Ramya Resorts Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

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

ITA 1937/BANG/2024[2014-15]Status: DisposedITAT Bangalore09 Jan 2026AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: None but written submissionFor Respondent: Shri Subramanian, Jt.CIT(DR)(ITAT), Bengaluru
Section 132Section 153CSection 234ASection 269SSection 271DSection 69C

there was also a receipt of Rs.46 lakhs. Thus, after giving a set off, it was found that Rs.1,51,39,853 is the undisclosed income of the assessee. Accordingly, the ld. AO divided into 4 different years as the amount of expenditure incurred

Sangeeta Motilal Shahani, Mumbai vs. ITO 27(3)(1), Vashi Navi Mumbai

ITA 7078/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Jan 2026AY 2013-14

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Jayant Bhatt, ARFor Respondent: Shri Asnkit Tiwari, Sr. AR
Section 143(1)Section 143(3)Section 68

thereafter selected for scrutiny under section 143(3) of the Act. After the deliberations the assessment was completed with an addition on account of undisclosed income under section 68 of the Act to the tune of Rs. 20,03,990/-, which was challenged by the assessee before the First Appellate

DCIT(CC)-8(3), Mumbai vs. Santosh Vimlesh Mehta, Mumbai

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

ITA 3725/MUM/2025[2012-13]Status: DisposedITAT Mumbai09 Jan 2026AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2012-13 Dcit(Cc)-8(3) Santosh Vimlesh Mehta Room No. 661 6Th Floor, Aaykar 10, Mumbadevi Road, Vs. Bhavan, Maharshi Karve Road, Mumbadevi, Mumbai-400002 Mumbai-400020 Mumbai Pan No. Abhpm 0883 H Appellant Respondent

For Appellant: Mr. Devendra JainFor Respondent: Mr. Virabhadra Mahajan, SR-DR
Section 10(38)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI ANIKESH

Nimus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5015/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

taxmann.com 328 (Jharkhand), held as under: Pursuant to a search of assessee's premises, Assessing Officer made an addition on ground of undisclosed Income on basis of loose sheets seized during search Whether loose sheets seized during search sometimes contain valuable information and thus those are to be regarded