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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

Assistant Commissioner of Income-Tax, Jaipur vs. Royal Jewellers, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

filed on 20.09.2017 whereas original return declaring income of Rs.3,95,19,200/- was filed u/s 139(1) on 15.09.2015 which include undisclosed income of Rs.3,94,67,426/-surrendered in survey operation u/s 133A conducted on 09.12.2014 at the business premises of the assessee situated at 1756, Telepada ... assessee on dated 09-12-2014 excess stock of Rs.3,94,67,426/-was found which was surrendered by the assessee as his undisclosed income for AY 2015-16 and incorporated the same in ITR for AY 2015-16 under head "income from business and profession" and the case

The Nashik Jilha Mahila Sahakari Bank Limited, Nashik vs. ACIT, Circle 1, Nashik

In the result, the appeal of the appellant is dismissed

ITA 1373/PUN/2025[2017-18]Status: DisposedITAT Pune24 Sept 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sanket JoshiFor Respondent: Shri Manish Kumar
Section 147Section 250

u/s.147 r.w.s.144 r.w.s.144B of the Act evenly 27.03.2022 and assessed income at Rs.94,59,633/- and Rs.1,35,01,936/- after making addition for undisclosed income at Rs.47,98,593/- and Rs.89,77,316/- for A.Ys. 2016-17 and 2017-18 respectively. 7. In the appeal filed before ld.CIT

The Nashik Jilha Mahila Sahakari Bank Limited, Nashik vs. ACIT, Circle 1, Nashik

In the result, the appeal of the appellant is dismissed

ITA 1372/PUN/2025[2016-17]Status: DisposedITAT Pune24 Sept 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sanket JoshiFor Respondent: Shri Manish Kumar
Section 147Section 250

u/s.147 r.w.s.144 r.w.s.144B of the Act evenly 27.03.2022 and assessed income at Rs.94,59,633/- and Rs.1,35,01,936/- after making addition for undisclosed income at Rs.47,98,593/- and Rs.89,77,316/- for A.Ys. 2016-17 and 2017-18 respectively. 7. In the appeal filed before ld.CIT

Exel Rubber Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, all the appeals of the assessee for the

ITA 1233/HYD/2025[2019-20]Status: DisposedITAT Hyderabad24 Sept 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

were found and seized in certain cases. After analysis of the seized material and investigation, the ADIT (Inv.), Unit-I(1) has quantified the undisclosed income detected in the hands of the assessee company M/s Exel Rubber Private Limited, as under: ‘Asst. Year [Undisclosed Income Additional Income admitted by Quantified ... ADIT ithe assessee out of the Undisclosed Income Detected 2014-15 3,46,53,599) 1,98,15,318| Note: If digitally signed, the date of digital signature may be taken as date of document. ,AAYKAR BHAWAN, OPPOSITE LB STADIUM, BASHEER BAGH, HYDERABAD, HYDERABAD, Telangana, 500004 Email: HYDERABAD.DCIT.CEN2@INCOMETAX.GOV.IN, ‘ Page

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1207/HYD/2025[2019-20]Status: DisposedITAT Hyderabad24 Sept 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CA
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

recorded placed at Page Nos. 9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that ... case of parallel books of account maintained by the assessee for recording the undisclosed income which are part of the books of account. He has also referred to the Explanation (1) to section 149(1) of the Act, as existed at the relevant point of time and submitted that

Exel Rubber Private Limited, K.V.Rangareddy vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1109/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

were found and seized in certain cases. After analysis of the seized material and investigation, the ADIT (Inv.), Unit-I(1) has quantified the undisclosed income detected in the hands of the assessee company M/s Exel Rubber Private Limited, as under: Asst. Year Undisclosed Income Quantified by ADIT Additional Income ... admitted by the assessee out of the Undisclosed Income Detected 2014-15 3,46,53,599 1,98,15,318 Note: If digitally signed, the date of digital signature may be taken as date of document. AAYKAR BHAWAN, OPPOSITE LB STADIUM, BASHEER BAGH, HYDERABAD, HYDERABAD, Telangana, 500004 Email: HYDERABAD.DCIT.CEN2@INCOMETAX.GOV.IN

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1108/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

were found and seized in certain cases. After analysis of the seized material and investigation, the ADIT (Inv.), Unit-I(1) has quantified the undisclosed income detected in the hands of the assessee company M/s Exel Rubber Private Limited, as under: Asst. Year Undisclosed Income Quantified by ADIT Additional Income ... admitted by the assessee out of the Undisclosed Income Detected 2014-15 3,46,53,599 1,98,15,318 Note: If digitally signed, the date of digital signature may be taken as date of document. ,AAYKAR BHAWAN, OPPOSITE LB STADIUM, BASHEER BAGH, HYDERABAD, HYDERABAD, Telangana, 500004 Email: HYDERABAD.DCIT.CEN2@INCOMETAX.GOV.IN, AAACE4495J

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1107/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Sept 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

were found and seized in certain cases. After analysis of the seized material and investigation, the ADIT (Inv.), Unit-I(1) has quantified the undisclosed income detected in the hands of the assessee company M/s Exel Rubber Private Limited, as under: Asst. Year Undisclosed Income Quantified by ADIT Additional Income ... admitted by the assessee out of the Undisclosed Income Detected 2014-15 3,46,53,599 1,98,15,318 Note: If digitally signed, the date of digital signature may be taken as date of document. ,AAYKAR BHAWAN, OPPOSITE LB STADIUM, BASHEER BAGH, HYDERABAD, HYDERABAD, Telangana, 500004 Email: HYDERABAD.DCIT.CEN2@INCOMETAX.GOV.IN, ==Start

Exel Rubber Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1106/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16
For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

were found and seized in certain cases. After analysis of the seized material and investigation, the ADIT (Inv.), Unit-I(1) has quantified the undisclosed income detected in the hands of the assessee company M/s Exel Rubber Private Limited, as under: Asst. Year Undisclosed Income Quantified by ADIT Additional Income ... admitted by the assessee out of the Undisclosed Income Detected 2014-15 3,46,53,599 1,98,15,318 Note: If digitally signed, the date of digital signature may be taken as date of document. AAYKAR BHAWAN, OPPOSITE LB STADIUM, BASHEER BAGH, HYDERABAD, HYDERABAD, Telangana, 500004 Email: HYDERABAD.DCIT.CEN2@INCOMETAX.GOV.IN, Page

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1088/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

reasons recorded placed at Page Nos.9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that ... case of parallel books of account maintained by the assessee for recording the undisclosed income which are part of the books of account. He has also referred to the Explanation (1) to section 149(1) of the Act, as existed at the relevant point of time and submitted that

Ace Tyres Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1087/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

recorded placed at Page Nos. 9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that ... case of parallel books of account maintained by the assessee for recording the undisclosed income which are part of the books of account. He has also referred to the Explanation (1) to section 149(1) of the Act, as existed at the relevant point of time and submitted that

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1086/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Sept 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

recorded placed at Page Nos. 9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that ... case of parallel books of account maintained by the assessee for recording the undisclosed income which are part of the books of account. He has also referred to the Explanation (1) to section 149(1) of the Act, as existed at the relevant point of time and submitted that

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1085/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.1084 To 1088 & 1027/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2014-15 To 2019-20)

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

reasons recorded placed at Page Nos.9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that ... case of parallel books of account maintained by the assessee for recording the undisclosed income which are part of the books of account. He has also referred to the Explanation (1) to section 149(1) of the Act, as existed at the relevant point of time and submitted that

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1084/HYD/2025[2014-15]Status: DisposedITAT Hyderabad24 Sept 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

recorded placed at Page Nos. 9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that ... case of parallel books of account maintained by the assessee for recording the undisclosed income which are part of the books of account. He has also referred to the Explanation (1) to section 149(1) of the Act, as existed at the relevant point of time and submitted that

Assistant Commissioner of Income Tax Circle 4(3)(1), Mumbai vs. Mohit Bharatiya, Mumbai

In the result, appeal of the assessee is allowed

ITA 3850/MUM/2025[2011-12]Status: DisposedITAT Mumbai24 Sept 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Satyaprakash Singh, CAFor Respondent: Shri Satyaprakash R. Singh, CIT DR and Shri Leyaqat Ali Aafaqui, Sr. AR
Section 143(3)Section 148Section 68

terms of section 68. When the nature and source of the amount so invested is known, it cannot be said to undisclosed income. Therefore, the addition of such subscriptions as unexplained credit under section 68 is unwarranted.” 6.5. Further, reliance is placed on the decision of Hon’ble Supreme Court

Saket Agarwal, Delhi vs. Income Tax Officer, Ward -45(2), Delhi

In the result, appeal of the assessee is partly allowed

ITA 6116/DEL/2024[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Shri Saket Agrawal, Vs Ito, 392/1, 2Nd Floor, Ward-45(2), Sainik Vihar, Pitam Pura, Delhi Delhi-110085. Pan-Aavpa3410D Appellant Respondent Appellant By Dr. Rakesh Gupta, Adv., Shri Somil Aggarwal, Adv. & Shri Saksham Aggarwal, Ca Respondent By Shri Narpat Singh, Sr. Dr Date Of Hearing 26.06.2025 Date Of Pronouncement 24.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 10.12.2024 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Delhi-15/10489/2019-20 U/S 250 Of The Income Tax Act,1961 [“The Act”] Arising Out Of Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Return Of Income On 26.03.2018, Declaring Total Income Of Inr 10,02,940/-. The Case Of The Assessee Was Selected For Complete Scrutiny For The Reason That Assessee Has Deposited Cash In Specified Bank Notes (Sbn) During Demonetization & Due To The Survey Carried Out At The Business Premises Of The Assessee.

Section 115BSection 143(3)Section 250Section 68Section 69C

assessee has challenged the addition of INR 3,14,94,237/- made on account of sales by treating the same as undisclosed income u/s 68 of the Act. 11. Before us, Ld.AR submits that all the sales were made through proper bills and such bills were produced for verification before

Income Tax Officer, Ward-3(2)(4), Muzaffarnagar vs. Shah Nawaz Rana, Muzaffarnagar

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

ITA 2865/DEL/2024[2016-17]Status: DisposedITAT Delhi24 Sept 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2016-17 Ito, Vs Shah Nawaz Rana, Ward 3(2)(4), 786, Meerut Road, Muzaffarnagar. New Rana House, Muzaffarnagar (Up). Pan: Abtpr6568E (Appellant) (Respondent) Assessee By : Shri Anil Kumar Jain, Advocate Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 16.09.2025 Date Of Pronouncement : 24.09.2025

For Appellant: Shri Anil Kumar Jain, AdvocateFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 147Section 148Section 68

received and analysis thereupon, leads to conclusion that above mentioned entries amounting to Rs. 11,21,91,653/- during the year under consideration represents undisclosed income of the assessee. Thus, the assessee concealed his income of Rs.11,21,91,653/- as the same has not offered for taxation ... supporting material, in my opinion, does establish any substantive link between the two, much less lead to the conclusion that the appellant had such undisclosed income. The laudable intention of avoiding loss of Revenue cannot be a reason to bypass logical reasoning and rational assessment of the material facts

Dairy India Private Limited, Delhi vs. Assistant Commissioner of Income Tax - Circle - 7(1), Delhi

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

ITA 1987/DEL/2024[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER and SHRIS.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Bhupinderjit Kumar, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 142(1)Section 143(2)Section 68

difference of cash sales and cash deposited for the period of demonetization the tax authorities have added the difference of the above as undisclosed income u/s 68 of the Act. In this regard, he submitted that the tax authorities failed to verify the books of account and assessee had opening

Ravish Vohra, New Delhi vs. DCIT Circle-20(2), New Delhi

The appeal is allowed

ITA 161/DEL/2023[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Dr. Rakesh Gupta, Shri Somil AgarwalFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(3)Section 44ASection 69A

sales by way of revising its VAT returns in the post-demonetisation period,' vii It has been held that the cash deposited was undisclosed income sought to be disguised as cash sales. viii. Without prejudice, it may kindly be noted that the sales figure was revised only once ... deposit of Rs.43 lacs without providing any justification or reasoning. ix. In the assessment order and computation sheet, the Ld.AO has added the alleged undisclosed income to the income declared by the assessee in the return. It maybe kindly be noted that the declared business income u/s 44AD already includes

Subhash Shah, Faridabad vs. ITO, Ward-2(4), Faridabad

In the result, the assessee’s appeal stand allowed in the aforesaid manner

ITA 1021/DEL/2019[2010-11]Status: DisposedITAT Delhi24 Sept 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singhsubhash Shah, Vs. Ito, Ward 2(4), Prop. M/S Fancy Cloth House, Faridabad, Haryana Mfc 5842, Sanjay Colony, Sector-23, Faridabad Haryana (Pan: Aynps4924N) (Appellant) (Respondent) Appellant By : Sh. Akul Agarwal, Fca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 22.09.2025 Date Of Pronouncement 24.09.2025 Order Per Mahavir Singh: This Appeal Has Been Filed By The Assessee Against The Order Dated 31.12.2018 Passed By The Ld. Cit(A), Faridabad Relating To Assessment Years 2010-11. 2. The First Issue In This Appeal Of The Assessee Is As Regards To The Action Of The Assessing Officer In Assuming Jurisdiction U/S. 147 R.W.S. 148 Of The Act As The Same Is Without Forming Reasonable Belief While

For Appellant: Sh. Akul Agarwal, FCAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(2)Section 147Section 148

believe that the income of the assessee has escaped assessment to the extent of Rs. 1,12,55,000/-. In order to bring undisclosed income to tax, proceedings u/s. 147 of the Income Tax Act, 1961, are being initiated in the case of the assessee.” 4. Consequent to reasons recorded