← All Phrases

“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

Kiran Bala Gupta, Hyderabad vs. ITO, Ward-10(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 341/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.341/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2012-13) Smt. Kiran Bala Gupta, Vs. Income Tax Officer, Hyderabad. Ward-10(1), Pan: Ahvpg6893K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Av Raghuram, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 20/12/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/08/2022 For The Assessment Year (Ay) 2012-13. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 10(38)Section 143(2)Section 143(3)Section 271(1)(c)

recharacterizing the sale of shares of M/s. Oasis Cine Communications Ltd by the assessee during the subject year as an unexplained cash credit under section 69A of the Act (after treating the sale transaction as genuine and declining of the assessee’s claim for exemption of long term capital gains ... resulting to the addition of Rs.1.86 crores (supra) and not on the basis that the same addition was found to be an unexplained cash credit under section 68 of the Act. 21. Be that as it may, as we have quashed the penalty imposed by the AO with respect

Satyanarayana Reddy Cheruku, Warangal vs. Income Tax Officer, Ward-1, Warangal

ITA 1358/HYD/2025[2010-11]Status: DisposedITAT Hyderabad20 Feb 2026AY 2010-11

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1358/Hyd/2025 (िनधा"रण वष"/Assessment Year:2010-11) Satyanarayana Reddy Vs. Income Tax Officer, Cheruku, Ward-1, Warangal. Warangal. Pan: Aaupc0479M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals)-12, Hyderabad, Dated 23/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) R.W.S 153C Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 11/12/2017 For The Assessment Year (Ay) 2010-11. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 143(3)Section 153CSection 69A

educational society for the admission of his son, i.e., over and above the prescribed fee, and made an addition of the same as unexplained cash credit under section 68 of the Act. 5. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1335/HYD/2025[2014-15]Status: DisposedITAT Hyderabad20 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

made an addition of Rs.87,87,661/- to the returned income of the assessee firm. The Assessing Officer also made an addition towards unexplained cash credits of Rs.21,16,089/- and further made an addition of Rs.1,87,113/- towards cash payments in excess of Rs.20,000/- under section

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1334/HYD/2025[2013-14]Status: DisposedITAT Hyderabad20 Feb 2026AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

made an addition of Rs.87,87,661/- to the returned income of the assessee firm. The Assessing Officer also made an addition towards unexplained cash credits of Rs.21,16,089/- and further made an addition of Rs.1,87,113/- towards cash payments in excess of Rs.20,000/- under section

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1333/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

made an addition of Rs.87,87,661/- to the returned income of the assessee firm. The Assessing Officer also made an addition towards unexplained cash credits of Rs.21,16,089/- and further made an addition of Rs.1,87,113/- towards cash payments in excess of Rs.20,000/- under section

Sama Narasimha Reddy and Sama Saraswathi Reddy Gardens, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

In the result, appeals filed by the assessee for AY 2011-12 to AY

ITA 1332/HYD/2025[2011-12]Status: DisposedITAT Hyderabad20 Feb 2026AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1332, 1333, 1334 &1335/Hyd/2025 ("नधा"रण वष"/A.Ys. 2011-12, 2012-13, 2013-14 & 2014-15) Sama Narasimha Reddy & Vs. Dcit, Sama Saraswathi Reddy Central Circle-1(2), Gardens, Hyderabad. Hyderabad. Pan: Aajfs7086H (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of 16/02/2026 Hearing: घोषणा क" तार"ख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)]-12, Hyderabad, Dated 15/07/2025, Pertaining To Assessment Year (“A.Y”) 2011-12 & A.Y 2012-13 Respectively & Learned Cit(A)’S Orders Dated 04/07/2025, Pertaining To A.Y. 2013-14 & A.Y. 2014-15 Respectively. Since The Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Are Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133ASection 145Section 147Section 148Section 148(2)Section 250

made an addition of Rs.87,87,661/- to the returned income of the assessee firm. The Assessing Officer also made an addition towards unexplained cash credits of Rs.21,16,089/- and further made an addition of Rs.1,87,113/- towards cash payments in excess of Rs.20,000/- under section

ITO-23(3)(6).Mumbai, Mumbai vs. Rajeshwar Bullion Trading, Mumbai

In the result, the appeal is dismissed

ITA 6132/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)
Section 115BSection 147Section 68

persons to whom sales were made, the A.O. has treated the cash deposits of Rs.38,92,692/- as M/s. Rajeshwar Bullion Trading ‘unexplained cash credit’ and added to the income of the assessee. It is evident, in course of proceedings before ld. First appellate authority, the assessee has again furnished

M/S. Rajeshwar Bullion Trading, Mumbai vs. Asst. CIT, Circle 23(3), Mumbai

In the result, the appeal is dismissed

ITA 5754/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)
Section 115BSection 147Section 68

persons to whom sales were made, the A.O. has treated the cash deposits of Rs.38,92,692/- as M/s. Rajeshwar Bullion Trading ‘unexplained cash credit’ and added to the income of the assessee. It is evident, in course of proceedings before ld. First appellate authority, the assessee has again furnished