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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

Assistant Commissioner of Income Tax, Madurai vs. Jayaraj Jaison, Tirunelveli

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

ITA 2512/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Jul 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:2512/Chny/2024 िनधा"रण वष" / Assessment Year: 2020-21 The Assistant Commissioner Of Jayaraj Jaison, Income Tax, Vs. No.9/10, Prop: Jaison Bkery, Central Circle -2, Madurai. Kavalkinaru, Tirunelveli – 625 002. (अपीलाथ"/Appellant) [Pan:Akgpj-2821-E] (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Gouthami Manivasagam, J.C.I.T. ""थ" की ओर से/Respondent By : Shri. R. Venkata Raman,C.A. सुनवाई की तारीख/Date Of Hearing : 02.07.2025 घोषणा की तारीख/Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: This Appeal Is Preferred By The Revenue Against The Order Dated 30.07.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals)-19, Chennai (‘Ld.Cit(A)’ In Short), Arising Out Of The Assessment Order Dated 30.09.2022 Passed U/S.143(3) Of The Income Tax Act, 1961 (‘The Act’ In Short) By The Assistant Commissioner Of Income Tax, Central Circle - 2, Madurai (‘Ao’ In Short), For The Assessment Year (‘Ay’ In Short) 2020-21. 2. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Ms. Gouthami Manivasagam, J.C.I.TFor Respondent: Shri. R. Venkata Raman,C.A
Section 131Section 133ASection 143(3)Section 68Section 69

building, cannot be treated as regular business income. The AO was of the view that this portion of the disclosure constituted unexplained cash credits and unexplained investment, respectively, and was therefore liable to be assessed under the provisions of section 115BBE of the Act, which prescribes a higher rate ... bakery and tea stall. Therefore, such liabilities are integrally linked to the business activity and cannot, by any stretch, be construed as unexplained cash credits or income from undisclosed sources. 32. We further observe that in order to address the discrepancies noted during the course of the survey, particularly with

Amico Textiles, Solan vs. DCIT CC-1, Chandigarth

The appeal stand partly allowed

ITA 431/CHANDI/2022[2014-15]Status: DisposedITAT Chandigarh16 Jul 2025AY 2014-15

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.431/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2014-15) M/S Amico Textiles Dcit Village Bir Plassi, Ropar Road, Central Circle-1 बनाम/ Vs. Nalagarh, Solan Chandigarh Himachal Pradesh 176077 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfa-9823-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Neeraj Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 23-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-03-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) Of The Act On 30-12-2016. The Substantial Grievance Of The Assessee Is Confirmation Of Addition Of Rs.63.27 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed Off As Under.

For Appellant: Sh. Neeraj Jain (CA) – Ld. ARFor Respondent: Sh. Manav Bansal (CIT) – Ld. DR
Section 132Section 143(3)Section 69

assessee has assailed another addition of Rs.2.47 Lacs as confirmed by Ld. CIT(A). The Ld. AO made addition of unexplained cash credits for Rs.21.89 Lacs on the basis of Annexure-2 as seized during search on partners. The same allegedly contained unaccounted receipts of the assessee which assessee denied