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“cash found during search”

Search & SeizureSection 132Section 132128 judgments

The decision most relied on for cash found during search is CIT v. Indeo Airways Pvt. Ltd. (349 ITR 85), cited in 114 judgments on BharatTax.

Leading authorities on cash found during search

CIT v. Indeo Airways Pvt. Ltd.
349 ITR 85 · 2012 · High Court
114
citing judgments

If revenue relies on entries of receipts in seized material, the corresponding expenditure must also be considered unless there is concrete evidence to disregard it. If documents found during a search are considered true and belong to the assessee, entries of expenditure recorded therein are also to be believed.

Rajesh Sunderdas Vaswani v. ACIT
76 Taxmann.com 311 · 2016 · High Court
57
citing judgments

Where a document found during a search is a copy of a ledger of an assessee company showing payments, the Assessing Officer has prima facie material to suggest satisfaction under section 153C was duly recorded, justifying a notice to the assessee.

449 (Madras), Sterling Machine Tools v. CIT
122 ITR 926 · High Court
22
citing judgments

Unexplained jewellery found during a search can be added to income, even if the assessee claims it was received back against purchase bills, especially when part of the unaccounted cash is deposited in the bank.

Sukh Ram v. ACIT
285 ITR 256 · 2006 · High Court
19
citing judgments

When a large sum of cash is found during a search, and the assessee fails to substantiate their claim that it belongs to an organization, the cash is treated as the assessee's own and added to their income under section 69A.

Ashokbhai H Jariwala v. ACIT
250 Taxmann 14 · 2017 · Supreme Court
18
citing judgments

Evidence found during a search and seizure operation under section 132(4) can be used to make additions under sections 68, 69, and 69A, even if the assessee's statement is retracted.

Prayag Tendu Leaves Processing Co. v. Commissioner of Income Tax
400 ITR 120 · 2018 · High Court
18
citing judgments

When assessing a partnership firm, the Assessing Officer can inquire into the source of credits introduced by partners, but cannot be compelled to investigate the 'source of the source' of those partners' funds under Section 68.

Principal Commissioner of Income-tax v. Buniyad Chemicals Ltd.
172 Taxmann.com 462 · 2025 · High Court
17
citing judgments

The addition of unexplained cash credits under section 68 requires the assessee to prove the genuineness of transactions beyond the banking channel. Incriminating material found during search or survey actions, such as admissions of providing accommodation entries, can be used to support such additions.

CIT v. Lakshmi Hospital
347 ITR 367 · Reported
12
citing judgments

Entries found on loose papers during a search cannot, on their own, be considered material for making an addition to income. Such additions require corroborative evidence and proper inquiry.

Judgments citing cash found during search

Meridian Marketers, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 1879/HYD/2025[2022-23]Status: HeardITAT Hyderabad06 Mar 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1879/Hyd/2025 Assessment Year 2022-2023 Meridian Marketers, The Acit, Hyderabad. Telangana. Central Circle-2(1), Vs. Pin 500 033. Hyderabad. Pan Abmfm1321M Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By -None- राज" व "ारा/Revenue By : Sri Mathivanan S A, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Sri Mathivanan S A, Sr. AR
Section 131Section 132ASection 139(4)Section 139(5)Section 148Section 148ASection 250Section 69A

Commissioner of Income Tax (Appeals)- 12, Hyderabad erred in sustaining the addition of Rs.35,00,000 made by the Assessing Officer treating the cash found during search as unexplained money u/s 69A. Ground No.3 The learned Commissioner of Income Tax (Appeals) 12, Hyderabad erred in not considering the fact that

Rakesh Kumar Vohra, Panchkula vs. Deputy Commissioner of Income Tax (Central Circle-2), Chandigarh, C.R. Building Chandigarh

The appeal stands partly allowed

ITA 1015/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh02 Feb 2026AY 2019-20
For Appellant: Sh. Dhruv Goel (CA) – Ld. ARFor Respondent: Sh. Bharat Bhushan Garg (CIT) – Ld. DR (Virtual)
Section 143(3)Section 69A

sole grievance of the assessee is confirmation of addition of Rs.5.50 Lacs u/s 69A which represent cash found during search on the assessee. The Ld. AR sought telescoping benefit out of surrender made by the partnership firm in which the assessee acted as partner to the extent

Deputy Commissioner of Income Tax, Delhi vs. Gaurav Dalmia, Delhi

In the result, additional ground 1 under Rule 27 of the assessee is

ITA 4162/DEL/2025[2016-17]Status: DisposedITAT Delhi29 Jan 2026AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 132(4)Section 153ASection 153DSection 69A

order) of Shri Mridu Hari Dalmia it may be observed that it has been admitted by ld AO that: i) Cash found during search pertains to A Y 2021-22 ii) The cash found is not related to wave group as the addition has been made ... respect of cash found during search separately. In view of the above the Id AO wrongly made adverse observation on the basis of cash found during search the addition in respect of which has been made separately in the A Y 2021-22 in the hands of Shri Mridu Hari

DCIT-CC-8(4), Mumbai vs. Akshay Jayantilal Doshi, Mumbai

ITA 6136/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokardcit-Cc-8(4), Akshayjayantilaldoshi Mumbai 701, Bhoomibldg, Jvpd Room No. 658, 6Th Vs. Scheme Vileparle, Floor, Mumbai- 400056 Aayakarbhawan, Mumbai- 400020, Mumbai Pan/Gir No. Aahpd2867K (Applicant) (Respondent) Assessee By Shri Akshay Jain Revenue By Shrisurendra Mohan, Sr. Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 27.01.2026 आदेश / Order Per Makarand Vasant Mahadeokar,Am: This Appeal Is Filed By The Revenue Against The Order Passed By The Learned Commissioner Of Income-Tax (Appeals)–50, Mumbai [Hereinafter Referred To As “Cit(A)”], Dated 31.07.2025, For Assessment Year 2022–23, Whereby The Learned Cit(A) Deleted The Addition Of Rs. 1,25,64,000/- Made By The Assessing Officer Under Section 69A Of The Income-Tax Act, 1961[Hereinafter Referred To As “The Act”] Vide Order Dated 02.06.2023 Passed Under Section 143(3) Of The Act.

Section 115BSection 132Section 143(3)Section 69A

accounts of various group entities as on the date of search was Rs. 2,16,68,169/-, which was more than the total cash found during search at different premises amounting to Rs. 2,15,77,500/-. The assessee also furnished details of cash-in-hand of family members ... books of accounts of various group entities as on the date of search was Rs. 2,16,68,169/-, whereas the total cash found during search was Rs. 2,15,77,500/-, and therefore the cash found was fully explained. It was further submitted that the books of accounts

Usha Girdharilal Jhunjhunwala, Mumbai vs. DCIT, Central Circle-1, Delhi

In the result, this ground

ITA 3499/DEL/2025[2021-22]Status: DisposedITAT Delhi05 Jan 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla

Section 143(3)Section 69A

upheld in the lower appellate discussion reading as under: “6 In Ground No 4 the appellant has contested the addition on account of cash found during search of Rs 54,13,000 u/s 69A of the Income Tax Act. 6.1 During the course of the search and seizure action, cash ... premise of Mr. Ashish Jhunjhunwala (son of the appellant) 6.13 As per the appellant it has been admitted in the impugned order that cash found during search was the accumulation of her past savings of household expenditure given to her for day to day for running of house

K C Raju Multi Speciality Hospital, Bangalore vs. DCIT, Central Circle-2(4), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1056/BANG/2025[2018-19]Status: DisposedITAT Bangalore19 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 139(1)Section 153ASection 234B

based solely on the statement recorded during the search but was supported by seized material, parallel books of account, cash found during search, and consistent admissions by the assessee. The explanation offered by the assessee was found to be unsatisfactory and unsubstantiated. Accordingly, the learned CIT(A) confirmed the action ... that the addition of ₹1,20,00,000/- made under section 69A of the Act is unsustainable in law and on facts. The cash found during search is fully explained and already offered to tax as part of regular business income. Therefore, the assessee prays that the learned

K C Raju Multi Speciality Hospital, Bangalore vs. DCIT, Central Circle-2(4), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1055/BANG/2025[2017-18]Status: DisposedITAT Bangalore19 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 139(1)Section 153ASection 234B

based solely on the statement recorded during the search but was supported by seized material, parallel books of account, cash found during search, and consistent admissions by the assessee. The explanation offered by the assessee was found to be unsatisfactory and unsubstantiated. Accordingly, the learned CIT(A) confirmed the action ... that the addition of ₹1,20,00,000/- made under section 69A of the Act is unsustainable in law and on facts. The cash found during search is fully explained and already offered to tax as part of regular business income. Therefore, the assessee prays that the learned

Deputy Commissioner of Income Tax, Central Circle 4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

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

ITA 1496/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

Ghanshyam Prasad Gupta, Muzaffarpur vs. ACIT, Central Circle, Muzaffarpur

In the result, the appeal of the assessee is allowed

ITA 152/PAT/2019[2013-14]Status: DisposedITAT Patna09 Dec 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: S/Shri A.K. RastogiFor Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 132(1)

IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA” BENCH, PATNA BEFORE SHRI DUVVURU RL REDDY, VP AND SHRI RAJESH KUMAR, AM

Sunil Kumar Gattani, Jaipur vs. The Asstt. Commissioner of Income Tax Central Circle - 2, Jaipur

In the result ground no. 7

ITA 1142/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 131Section 132Section 132(4)Section 143(3)Section 69Section 69A

appellant could not explain the source of this cash found. During assessment proceedings, the appellant was asked to furnish the source of cash found during search of Rs.1,56,15,565/- (Rs.1,22.50,000/- Rs.33.65,565/-) The appellant stated that source of the cash found was from brokerage income ... action of Id. CIT(A) in confirming the addition of Rs.1,56,15,565/- u/s 69A made by Id. AO on account of cash found during search, which basically represented undisclosed income of assessee for preceding years from finance brokerage and has also challenged the invocation of provisions of section

Ritu Singhal, Dehradun vs. DCIT/ACIT, Central Circle, Dehradun

In the result, appeal of the assessee is allowed

ITA 47/DDN/2025[2022-23]Status: DisposedITAT Dehradun29 Oct 2025AY 2022-23

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(3)Section 147Section 250Section 69A

ITA No.42/DDN/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER & SHRI

DCIT-CC-6(1), Mumbai, Bkc, Kautilya Bhawan vs. Prashant Prakash Nilawar, Pune

In the result, the appeal of the Revenue, being ITA

ITA 2896/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Appellant: 1.1. On the facts and circumstances of the case and in law
Section 69ASection 69BSection 69C

upheld in entirety. 58. We shall now turn to the remaining issues relating to additions under section 69A on account of cash found during search, which are the subject of both appeals. 59. We now proceed to examine the next issue arising from the addition made on account of cash ... directly reconciled with the sources explained. 63. We have carefully perused the orders of the authorities below and considered the submissions. The total cash found during search amounted to ₹54,29,800, whereas the explained cash available from the two sources the LLP and the father aggregated to more than

Prashant Prakash Nilawar, Pune vs. ACIT Circle-6(1), Nariman Point Mumbai

In the result, the appeal of the Revenue, being ITA

ITA 2318/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23
For Appellant: 1.1. On the facts and circumstances of the case and in law
Section 69ASection 69BSection 69C

upheld in entirety. 58. We shall now turn to the remaining issues relating to additions under section 69A on account of cash found during search, which are the subject of both appeals. 59. We now proceed to examine the next issue arising from the addition made on account of cash ... directly reconciled with the sources explained. 63. We have carefully perused the orders of the authorities below and considered the submissions. The total cash found during search amounted to ₹54,29,800, whereas the explained cash available from the two sources the LLP and the father aggregated to more than

M/S Sushila Devi Centre for Professional Studies and Research, Dehradun vs. PCIT (Central), Kanpur (Jao- Dy. Commissioner of Income Tax, Central Circle, Dehradun)

ITA 131/DDN/2025[2024-25]Status: DisposedITAT Dehradun17 Oct 2025AY 2024-25

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 12Section 127Section 127(2)(a)Section 12ASection 132Section 143(3)

application of funds for non-charitable purposes. 15. That the cancellation of registration solely on the basis of alleged unverified diaries and cash found during search, without a finding of diversion of income or misuse of exemption under Sections 11 and 12, is unjustified, excessive and contrary to the scheme

Sunil Kumar Jain, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 616/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Sept 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Rajesh VaishnavFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 115BSection 131Section 142(1)Section 143(2)Section 143(3)

Department was offered to tax under the head "Income from business or Profession". The assessee has failed to furnish explanation for the cash found during search by the Department. Further, the assessee is filing returns with estimated income from business. The income declared by the assessee is very nominal

Puran Mal Agarwal, Jaipur vs. Asstt. Commissioner of Income Tax, Central Circle-2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 789/JPR/2025[2019-20]Status: DisposedITAT Jaipur09 Sept 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vijay Goyal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 115BSection 132(4)Section 139oSection 143(3)Section 250Section 44ASection 69A

excess Jewellery and Cash respectively and the addition to the tune of Rs. 5,00,136/- was confirmed on a/c of unexplained cash found during search. Further, Ld. CIT (A) also confirmed the invocation of provisions of section 115BBE of the Act on the addition ... addition of Rs. 5,00,136/- out of total addition of Rs. 20,96,136/- made by the ld AO against the cash found in search u/s 69A and charging the tax by applying provisions of section 115BBE. 2. The appellant prays for leave to Add, to amend, to delete

Deputy Commissioner of Income Tax, Hubballi vs. Shri Krishna Mohan Kalburgi, Hubballi

ITA 1137/BANG/2024[2019-20]Status: DisposedITAT Bangalore13 Aug 2025AY 2019-20

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

For Appellant: Shri. Sheshadri Chalapati, ARFor Respondent: Shri. Shivanad Kalakeri, CIT(DR)(ITAT), Bangalore
Section 10Section 132Section 132(4)Section 143(1)Section 143(2)Section 153C

During the course of search conducted sworn statement under Section 132(4) of the Act on 19.01.2019 was recorded with regard to unexplained cash found during search, it was stated that the cash is out of on- money received by him on sale of residential flats and commercial premises. Accordingly

Deputy Commissioner of Income Tax, Hubballi vs. Shri Krishna Mohan Kalburgi, Hubballi

ITA 1136/BANG/2024[2018-19]Status: DisposedITAT Bangalore13 Aug 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

For Appellant: Shri. Sheshadri Chalapati, ARFor Respondent: Shri. Shivanad Kalakeri, CIT(DR)(ITAT), Bangalore
Section 10Section 132Section 132(4)Section 143(1)Section 143(2)Section 153C

During the course of search conducted sworn statement under section 132(4) of the Act on 19.01.2019 was recorded with regard to unexplained cash found during search, it was stated that the cash is out of on- money received by him on sale of residential flats and commercial premises. Accordingly

Mohd. Alam, Moradabad vs. DCIT, Circle- 1, Moradabad

Appeal of the assessee is dismissed

ITA 4519/DEL/2019[2015-16]Status: DisposedITAT Delhi09 Jul 2025AY 2015-16

Bench: Ms.Madhumita Roy & Shri Manish Agarwal

Section 131Section 142(1)Section 143(3)Section 153ASection 250(6)

ITA Nos.4519 & 4520/Del/2019 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “E” BENCH: NEW DELHI BEFORE MS.MADHUMITA ROY, JUDICIAL MEMBER & SHRI

Sahodhar Reddy Muddasani, Hyderabad vs. DCIT, Central Circle - 1(3), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 444/HYD/2025[2019-20]Status: DisposedITAT Hyderabad07 Jul 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA K C Devdas And Shri C Maheshwar ReddyFor Respondent: Shri Waseem UR Rehman, Sr. AR
Section 132Section 143(3)Section 69A

assessee. The learned CIT(A) in second round of litigation, after considering relevant details filed by the assessee in support of source for cash found during search, rejected the explanation of assessee and upheld the addition made by the Assessing Officer towards cash found during search u/sec.69A of the Income ... along with relevant evidences. However, the Assessing Officer and the learned CIT(A) without considering the evidences, simply sustained the addition made towards cash found in search. Thus, he submitted that, addition made by the Assessing Officer should be deleted. 8. Shri Waseem UR Rehman, learned Sr. AR for Revenue