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“unexplained cash credit”

Cash Credits & Unexplained ItemsSection 68Section 687,118 judgments

The decision most relied on for unexplained cash credit is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on unexplained cash credit

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Orissa Corporation Pvt. Ltd.
159 ITR 78 · 1986 · Supreme Court
897
citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull
87 ITR 349 · 1973 · Supreme Court
525
citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

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.

Judgments citing unexplained cash credit

Jigar Patel, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 604/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad06 Oct 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: NoneFor Respondent: Shri B.P Srivastava, Sr DR
Section 143(3)Section 68

erred in law and on facts in confirming addition of Rs.49,55,101/- made by the learned ITO (Assessment Unit) as unexplained cash credit u/s.68 of the Act. The Addition confirmed by the learned CIT(A) NFAC deserves to be deleted. The same be deleted now. 2. The Learned ... income from the unexplained sources shown as agricultural income and Rs.49,55,101/- (i.e. Rs.75,54,376 – Rs.25,99,275) was treated as unexplained cash credit u/s.68 of the Act. 4. Aggrieved assessee filed an appeal before the Ld.CIT(A), who dismissed the appeal of the assessee by observing

Ranar Agrochem Limited, Parawada vs. Deputy Commissioner of Income Tax, Visakhapatnam

ITA 288/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam31 Aug 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.288/Viz/2024 (िनधा"रण वष"/Assessment Year:2014-15) Ranar Agrochem Limited, Vs. Deputy Commissioner Visakhapatnam. Of Income Tax, Visakhapatnam. Pan: Aaccp0372M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M. Madhusudan, Ca (Hybrid) राज" व "ारा/Revenue By: Sri Jenardhanan V, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 14/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 15/05/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short “The Act”) Dated 30/12/2016 For A.Y.

For Appellant: Shri M. Madhusudan, CAFor Respondent: Sri Jenardhanan V, CIT-DR
Section 143(2)Section 143(3)Section 250Section 36(1)Section 36(1)(va)Section 40Section 68

Form No. 26AS vis-à-vis books of account of Rs. 1,35,680/-; and (iv) addition of the unsecured loans as unexplained cash credits under section 68 of the Act: Rs. 3,47,97,000/-. 4 Ranar Agrochem Limited vs. DCIT 4. Aggrieved, the assessee company carried the matter ... prove the remaining unsecured loans amounting to Rs. In the absence of 3,47,97,000/- the A.O held the same as unexplained cash credits u/s. 68 of the Act. The appellant submitted that the amounts were added representing the unsecured loans accepted by it and they are capital receipts

Chitra Avdhesh Mehta, Mumbai vs. ITO 33 (1) (3), Mumbai

In the result the appeal filed by the assessee stands

ITA 3229/MUM/2023[2014-15]Status: DisposedITAT Mumbai31 Aug 2026AY 2014-15

Bench: Hon’Ble Shri Sandeep Gosain

Section 10(38)Section 115BSection 143(3)Section 250Section 68

reproduced here in below: 1. In this appeal, the only disputed issue is regarding the addition made of Rs.84,79,100/- as unexplained cash credit u/s 68 of the act. The relevant facts are that during the year under consideration, the appellant sold certain shares and declared long term capital ... above mentioned purported share sale receipts during the FY 2013-14 (AY 2014-15) in his Capital Account as her income being the unexplained cash credit u/s 68 of the Act and has assessed her total income at Rs.89,34,040/-, the said additions were also upheld by CITA

ACIT-23(1), Mumbai vs. Gordhanbhai Govindbhai Kakadiya, Mumbai

In the result, the appeal filed by the revenue bearing ITA

ITA 5333/MUM/2024[2016]Status: DisposedITAT Mumbai31 Aug 2026

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeeacit-23(1), Mumbai Vs Gordhanbhai Govindbhai Kakadiya Room No.511, 5Th Floor Bc-2010, G Block Bharat Diamond Piramal Chambers, Lalbaug, Bourse, Bandra Kurla Complex, Lower Parel, Mumbai-400 012 Bandra (E), Mumbai-400 051 Pan: Agypk2399A Appellant Respondent

For Appellant: NoneFor Respondent: Shri Arun Kanti Datta – CIT DR
Section 147Section 250Section 68Section 69C

deleted the additions on account ' of LTCG and commission; • Uphold the assessment order in treating Rs.2,56,01,928/- as taxable income (unexplained cash credit) and Rs. 12,80,0967- as unexplained expenditure; 6 ITA 5333/Mum /2045 Gordhanbhai Govindbhai Kakadiya • Consequently, deny the exemption under Section

Sreepathy Trust, Thrissur vs. Commissioner of Income Tax Cirle 1(1), Thrissur

In the result, both the captioned appeals are dismissed

ITA 66/COCH/2024[2016-2017]Status: DisposedITAT Cochin10 Aug 2026AY 2016-2017

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr AR
Section 12ASection 143(3)Section 148Section 68

Officer made an addition of ₹1,37,19,323 to the returned income under Section 68 of the Act, treating the same as unexplained cash credit. The reassessed total income was computed at ₹3,40,53,543. 3. Aggrieved by the assessment order, the assessee preferred an appeal before ... 66/Coch/2024 – This appeal arises on similar facts for the assessment year 2016–17. The principal issue involved is again related to unexplained cash credit under Section 68, involving an amount of ₹1231760. The assessee has raised similar contentions as in the earlier appeal. As the facts and issues are identical

Sreepathy Trust, Thrissur vs. CIT, Circle 1, Thrissur

In the result, both the captioned appeals are dismissed

ITA 65/COCH/2024[2013-14]Status: DisposedITAT Cochin10 Aug 2026AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr AR
Section 12ASection 143(3)Section 148Section 68

Officer made an addition of ₹1,37,19,323 to the returned income under Section 68 of the Act, treating the same as unexplained cash credit. The reassessed total income was computed at ₹3,40,53,543. 3. Aggrieved by the assessment order, the assessee preferred an appeal before ... 66/Coch/2024 – This appeal arises on similar facts for the assessment year 2016–17. The principal issue involved is again related to unexplained cash credit under Section 68, involving an amount of ₹1231760. The assessee has raised similar contentions as in the earlier appeal. As the facts and issues are identical

DCIT, New Delhi vs. Vishwanath Singhal, Delhi

In the result, the appeal of the revenue is dismissed

ITA 2028/DEL/2025[2018-19]Status: DisposedITAT Delhi31 Jul 2026AY 2018-19

Bench: Shri M. Balaganeshacit, Vs. Vishwanath Singhal, Circle-58(1), 40, Priya Enclave, Delhi Delhi Pan: Aasps988Ik Assessee By : Shri Neeraj Mangla, Ca Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 10(38)Section 115BSection 133(6)Section 147Section 148Section 68

appeal of the revenue is as to whether the learned NFAC was justified in deleting the addition made on account of unexplained cash credit under section 68 of the Act in the sum of Rs 28,91,775/- in the facts and circumstances of the instant case. 3. I have ... account of long-term capital gains on sale of shares and brought the same to tax as unexplained cash credit under section 68 read with section 115BBE of the Act in the sum of Rs. 28,91,775/-. 4. The assessee submitted before the Learned NFAC that the Learned

DCIT Circle-10(1), New Delhi vs. Ghaziabad Organics Ltd., New Delhi

Appeal is partly allowed for statistical purposes

ITA 5894/DEL/2019[2015-16]Status: DisposedITAT Delhi15 Jul 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2015-16 Vs. Ghaziabad Organics Ltd., Dcit, Circle-10(1), C-73, Malviya Nagar, New Delhi New Delhi Pan: Aaacg6468R (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 26.05.2025 Date Of Pronouncement 26.05.2025 Order

Section 133(6)Section 143(3)Section 41(1)Section 68

finding of the AO. The addition amounting to Rs. 3,08,55,000/- has been made under Section 68 of the Act for unexplained cash credit. As per the AO the assessee has received unsecured loan from four parties and was not able to substantiate the identity and creditworthiness ... appeal is allowed.” 5. Mr. Dhanesta vehemently argues that the Assessing Officer had rightly treated the assessee’s above unsecured loans as unexplained cash credits as it had failed to prove the genuineness and creditworthiness thereof during “scrutiny. His further case is that mere filing of documentary evidence

Sh Sanjay Bansal, Morena vs. A.C.I.T (Central), Gwalior

In the result, assessee's appeal is dismissed

ITA 31/AGR/2022[2012 - 13]Status: DisposedITAT Agra05 Jun 2026

Bench: learned CIT(Appeals) who has very exhaustively passed the impugned order in 60 pages and considered all the submissions of the assessee in the tabulated form and otherwise, which need not to be repeated again for the sake of brevity. However, learned CIT(Appeals) partly allowed assessee's appeal confirming the addition only to the extent of Rs.71,44,045/- as against addition of Rs.91,06,669/-. 4. Assessee is in appeal before the Tribunal on the following grounds : "1.Because in any view, th

Section 143(3)Section 147Section 148Section 250Section 69

assessee is as to whether learned CIT(Appeals) has erred in partly confirming the addition to the extent of Rs.71,44,045/- as unexplained cash credits u/s. 69A of the Act. We have gone through the impugned order which has been passed by 7. Id. CIT(Appeals) in detail

M/S Surajhban Oils Pvt.Ltd, Morena vs. ACIT- (Central Circle), Gwalior

Appeals is partly allowed in above terms

ITA 45/AGR/2022[2017-18]Status: DisposedITAT Agra25 May 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalita No. 45/Agr./2022 (Assessment Year 2017-18)

For Appellant: NoneFor Respondent: Sh. Shailender Shrivastava, Sr. DR
Section 131Section 143(3)Section 68

Learned departmental representative vehemently argues in the light of both the lower authorities respective findings that they have rightly made Section 68 unexplained cash credit additions of Rs.80.60 lacs in the assessee’s hands, in the course of assessment framed on 28.12.2019 and upheld by the CIT(A) as under

Manish Jain, Delhi vs. Income Tax Officer, Delhi

The appeal of the assessee is allowed partly

ITA 3203/DEL/2024[2017-18]Status: DisposedITAT Delhi20 May 2026AY 2017-18

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

For Appellant: Shri Sanjay Kumar, CA; &For Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 143(3)Section 68

money. In the above circumstances and considering the fact that the appellant himself has offered to admit 15% of the cash deposited as unexplained cash credits, I do not find any merit in the appellant case and confirm the addition of Rs.75,00,000 made by the assessing officer

Kamla Associates, Sheopur vs. ACIT-3(1), Gwalior

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

ITA 371/AGR/2025[2011-12]Status: DisposedITAT Agra09 Apr 2026AY 2011-12

Bench: Shri M. Balaganeshkamla Associates, Vs. Acit, Pali Road, Sheopur, Circle-3(1), Mp Gwalior Mp (Appellant) (Respondent) Pan: Aaffk5366A Assessee By : Shri Anurag Sinha, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/03/2026 Date Of Pronouncement 17/03/2026

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 143(3)Section 68

confirmation of addition by the Learned CIT(A) of Rs 87,58,300 under section 68 of the Act on account of alleged unexplained cash credits in respect of advances received against sale of tractors. 3. We have heard the rival submissions and perused the materials available on record ... Learned AO proceeded to treat the advance received from customers in the sum of Rs. 1,05,65,000 as unexplained cash credit and added the same to the total income of the assessee. 4. We find that before the Learned CIT(A), the assessee had explained the complete facts

Bhawna Kapoor, New Delhi vs. ACIT Circle-62(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 632/DEL/2020[2014-15]Status: DisposedITAT Delhi09 Apr 2026AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarsmt. Bhawna Kapoor Vs. Acit Prop M/S Manish Circle 62(1) Handicraft 1196, Main Delhi Bazar, Paharganj, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adxpk 3853 F Appellant .. Respondent

For Appellant: Sh. Ramesh Chander, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 250(6)Section 68Section 69A

erred on facts and in law in treating the long-term capital gain of INR 33,97,009/- as unexplained cash credit u/s 68 of the Income-tax Act, 1961 ['the Act'} despite the fact that the said long-term capital gains is on account of sale of long term

ITO Ward - 52(5), New Delhi vs. Inderpal Singh L/H of Late Shri Raghbir Singh, New Delhi

In the result, the appeal filed by the Department of Revenue is allowed

ITA 1165/DEL/2020[2009-10]Status: DisposedITAT Delhi09 Apr 2026AY 2009-10
Section 139Section 142(1)Section 143(1)Section 147Section 148Section 151Section 250Section 68

circumstances of the case, the Ld. CIT(A) has erred in deleting the addition of Rs.1,97,83,000/- made on account of unexplained cash credit u/s 68 of the I.T. Act, without appreciating the findings of the AO. 2. The Ld. CIT(A) has erred in deleing the addition ... Departmental Representative submitted that Ld. CIT(A) erred in deleting additions of Rs.1,97,831/- made on account of unexplained cash credit u/s 68 of the Act, despite of the fact that assessee had introduced cash in his capital account which was proved bogus. 6. At the time of hearing

H R Motors, Himatnagar vs. Deputy Commissioner of Income Tax, Ahmedabad

In the result, the appeal filed by the Assessee is hereby allowed

ITA 1764/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 68

single day cash receipts is not acceptable thereby made addition of Rs.1,57,76,639/- as the income of the assessee as unexplained cash credit u/s. 68 of the Act. 3. Aggrieved against the assessment order, assessee filed an appeal before Ld. CIT(A) who has confirmed the addition made ... before us raising the following Grounds of Appeal: 1. The Ld. CIT(A) erred in confirming addition of Rs.1,57,76,639 as unexplained cash credit. It is submitted that entire amount received and deposited are from different customer who has booked the two-wheeler/ vehicles with appellant

DCIT-4(1), Indore vs. Rajat Sureka, Indore

The appeal is allowed

ITA 426/IND/2025[2014-15]Status: DisposedITAT Indore20 Mar 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Dcit 4(1), Rajat Sureka, Indore D-41, Hig Colony, बनाम/ A.B. Road, Vs. Indore (Revenue/Appellant) (Assessee/Respondent) Pan: Aksps7189J Revenue By Shri Ashish Porwal, Sr. Dr Assessee By Shri Subhash Chandra, Ar Date Of Hearing 19.03.2026 Date Of Pronouncement 20.03.2026

Section 139Section 147Section 148Section 68Section 69Section 69C

making an addition of Rs. 10,00,000/- treating the loan taken by assessee from ‘M/s Jayant Securities and Finance Pvt. Ltd.’ as unexplained cash credit u/s 68 (+) an addition of Rs. 20,000/- u/s 69C on account of unexplained payment of estimated commission for arranging accommodation of loan entry

Narayan Barter Private Limited, Kolkata vs. Income Tax Officer, Ward-6(1), Kolkata

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

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

were issued and a show cause notice dated 07.12.2018 was also issued seeking explanation for the alleged unexplained cash credit. Since the assessee failed to provide satisfactory explanation regarding the identity, creditworthiness, and genuineness of the creditors and the transactions, the Ld. AO treated the amount as unexplained cash credit ... assessee had contended that this was not a case of fresh credits and the addition made on account of unexplained cash credit was erroneous and the transactions merely involved conversion of one current asset into another and as ITA No(s). 2572/KOL/2025 Assessment Year(s) 2011-12 Narayan Barter Private

Neeraj, Faridabad vs. Pr, CIT, Faridabad

In the result, appeal filed by the assessee stands allowed

ITA 939/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Mar 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 144Section 144BSection 147Section 148Section 263Section 44ASection 68Section 69A

income of the assessee under section 69A (though there were specific directions of the Pr. CIT was to consider the case as unexplained cash credit within the meaning of under section 68 of the Act) of the Act at Rs.32,76,780/- against the returned income of Rs.3 ... explain the deposits of Rs.29,67,900/- Therefore, the Assessing Officer is directed to charge the tax on the same considering as unexplained cash credit within the meaning of uls 68 of the Income Tax Act, 1961...” Page 4 of 12 ITA Nos.928 and 929/Del/2025 6. The ld. Counsel

Neeraj, Faridabad vs. ITO, Ward-2(1), Faridabad

In the result, appeal filed by the assessee stands allowed

ITA 938/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Mar 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 144Section 144BSection 147Section 148Section 263Section 44ASection 68Section 69A

income of the assessee under section 69A (though there were specific directions of the Pr. CIT was to consider the case as unexplained cash credit within the meaning of under section 68 of the Act) of the Act at Rs.32,76,780/- against the returned income of Rs.3 ... explain the deposits of Rs.29,67,900/- Therefore, the Assessing Officer is directed to charge the tax on the same considering as unexplained cash credit within the meaning of uls 68 of the Income Tax Act, 1961...” Page 4 of 12 ITA Nos.928 and 929/Del/2025 6. The ld. Counsel

DCIT, Circle- 19(1), Delhi vs. Pashupati Road Carrier Pvt. Ltd., Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 2490/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumardcit, Circle 19(1), Vs. Pashupati Road Carrier Delhi Pvt. Ltd., Room No. 221, 2Nd Floor, Plot No. 70A/47, Ground C.R. Building, Floor, Moti Nagar, I.P. Estate, New Delhi – 110 002 Rama Road Indl. Area, New Delhi – 110 045 (Pan: Aadcp8319H) (Appellant) (Respondent) Assessee By : Sh. Baldev Raj, Ca & Sh. Manish Upneja, Ca Revenue By : Sh. Rajesh Kumar Dhanesta, Sr. Dr. Date Of Hearing : 24.02.2026 Date Of Order : 20.03.2026 O R D E R Per Sudhir Kumar, Jm :

For Appellant: Sh. Baldev Raj, CA & Sh. Manish UpnejaFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 115JSection 133(6)Section 143(2)Section 143(3)Section 40A(3)Section 68

Accordingly, the assessment was completed by making an addition of Rs. 1,08,97,000/- u/s. 68 of the Act on account of unexplained cash credits. Aggrieved by the additions, the appellant has filed the appeal. 7.1 Now, countering the arguments of the AO, the appellant has made a detailed ... section 40A(3) of the Act. 7.2 Since the core issues involved is of addition made u/s. 68 on account 3 of unexplained cash credits in nature of cash deposit in the bank account, it is imperative to look upon the ratios laid down by the various Hon'ble Courts