Section 104
Section 104: unexplained asset
Section 104 works like Section 103, but for assets rather than investments. If an assessee is found to own an asset that is not recorded in their books, or the amount spent acquiring it exceeds what is recorded, and the nature and source cannot be satisfactorily explained, the value of the asset (or the excess) is deemed to be the assessee's income.
What Section 104 says
Where in any tax year an asset is found to be owned by or belonging to the assessee that is not recorded in the books of account (if any) maintained for any source of income, or the Assessing Officer finds that the amount spent acquiring the asset exceeds the amount recorded in the books, and the assessee either offers no explanation about the nature and source of acquisition of the asset or the excess amount, or the explanation offered is not found satisfactory by the Assessing Officer, then the value of the asset, or the excess amount, is deemed to be the assessee's income of the tax year in which the asset is found to be owned by or belonging to the assessee.
What counts as an "asset"
For this section, "asset" includes money, bullion, jewellery, virtual digital asset, or other valuable article.
Frequently asked questions
What kinds of assets does Section 104 cover?
Money, bullion, jewellery, virtual digital assets, or any other valuable article that is found to be owned by the assessee but is not recorded in their books.
In which year is the unexplained asset taxed?
In the tax year in which the asset is found to be owned by or belonging to the assessee.
Related sections
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Get help responding to an unexplained asset queryLast updated 9 September 2026