← 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

Trikkalangode Vanitha Cooperative Society Ltd, Malappuram vs. ITO, Ward 1, Tirur

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

ITA 958/COCH/2024[2019-20]Status: DisposedITAT Cochin31 Jul 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2019-20 Thrikkalangode Vanitha Co-Op. Society Ltd. .......... Appellant Thrikkalangode, Malapuram 676123 [Pan: Aafat1812K] Vs. The Income Tax Officer, Ward-1., Tirur .......... Respondent Appellant By: Shri Arjun Nedungadi, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 09.06.2025 Date Of Pronouncement: 31.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 30.09.2024 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. No Regular

For Appellant: Shri Arjun Nedungadi, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139Section 139(1)Section 147Section 148Section 68Section 69Section 69ASection 80ASection 80P

made in the account maintained with Manjari Co-operative Urban bank Ltd. as unexplained money of the appellant. Also made addition of unexplained cash credit of Rs. 26,03,873/- and interest income of Rs. 3,62,465/- for the failure of the assessee to explain and substantiate the source

Zahir Iqbal Laliwala, Ahmedabad vs. The ACIT, Circle-4(1)(1), Ahmedabad

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

ITA 394/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R Senthil Kumarzahir Iqbal Laliwala, The Assistant Vs. Aman, Opp. Paras Baug Soc. Commissioner Of Income B/H. Tagore Hall, Tax, Paldi, Circle-4(1)(1), Ahmedabad-380007. Ahmedabad. [Pan :Aafpl5516 R] (Appellant) .. (Respondent) Appellant By : Shri Hardik Vora, Ar Respondent By: Shri Hargovind Singh, Sr. Dr Date Of Hearing 30.07.2025 Date Of Pronouncement 31.07.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- Delay Condoned This Appeal Has Been Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [Cit(A)], Passed Under Section 250 Of The Income-Tax Act, 1961 (“The Act” For Short), Dated 26.07.2023, For The Assessment Year 2011–12, Whereby The Ld. Cit(A) Not Only Confirmed The Addition Of ₹1,26,89,915/- Made By The Assessing Officer (Ao) Under Section 68 Of The Act, But Also Enhanced The Same To ₹2,60,80,590/- Based On The Income Reflected In Form No. 26As.

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Hargovind Singh, Sr. DR
Section 144Section 147Section 250Section 68

well as law on the subject, the learned CIT(A) has erred in confirming the addition of Rs. 1,26,89,915/- as unexplained cash credits u/s.68 based on credit entries in the bank account. 4. On the facts and circumstances of the case as well

DCIT, Delhi vs. Shalimar Corp. Limited, Mumbai

ITA 2502/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

unsecured loans of 4 | P a g e ITA Nos.2360/Del/2023; 2764 to 2768/Del/2022; ITA Nos.2502/Del/2023; 2853 & 2854/Del/2022 Rs.4,05,00,000/- treated as unexplained cash credits under section 68, unexplained receipts, non-deduction of TDS, cash payments disallowances; involving varying sums, respectively. The Assessing Officer thus enhanced the assessee ... assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both

Shalimar Corp Limited, Delhi vs. DCIT, Central Circle-30, New Delhi

ITA 2360/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

unsecured loans of 4 | P a g e ITA Nos.2360/Del/2023; 2764 to 2768/Del/2022; ITA Nos.2502/Del/2023; 2853 & 2854/Del/2022 Rs.4,05,00,000/- treated as unexplained cash credits under section 68, unexplained receipts, non-deduction of TDS, cash payments disallowances; involving varying sums, respectively. The Assessing Officer thus enhanced the assessee ... assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both