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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

Pammi Jaiswal, Kolkata vs. Income Tax Officer-33(2)/Kolkata, Kolkata

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

ITA 2415/KOL/2024[2018-19]Status: DisposedITAT Kolkata26 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2415/Kol/2024 Assessment Year: 2018-2019 Pammi Jaiswal,………………….………..………Appellant 75/B, 4Th Floor, Uttar Panchanangram Mart, Vip Nagar, W.B. Pin Code No. 700100 [Pan:Bcnpj3281N] -Vs.- Income Tax Officer,……………………………...Respondent Ward-33(2), Kolkata, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri Debesh Poddar, A.R., Appeared On Behalf Of The Assessee Shri Susanta Saha, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 25, 2025 Date Of Pronouncing The Order: June 26, 2025 O R D E R

Section 142(1)Section 142(1)(i)Section 147Section 148Section 271ASection 68

documents and written submission. Without getting no response/explanation from the assessee, the ld. Assessing Officer treated the amount of Rs.54,76,300/- as unexplained cash credit under section 68 and added to the total income of the assessee at Rs.5,47,630/- @ 10% as commission income as the assessee furnished ... disregard for due process and the categorical and willful disinterest demonstrated by the appellant, the addition of Rs.5,47,630/- on account of unexplained cash credits made u/s 68 of the Income Tax Act are hereby confirmed. Accordingly, the ground of appeal of the appellant is dismissed”. Therefore, by considering

DCIT, Circle 7(1), Delhi vs. Dandona Finance Limited, Delhi

Appeal is dismissed

ITA 1310/DEL/2024[2017-18]Status: DisposedITAT Delhi26 Jun 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 1310/Del/2024 : Asstt. Year : 2017-18 Dcit, Vs Dandona Finance Ltd., Circle-7(1), 1701-1702, Partap Street, New Delhi-110002 Chuna Mandi, Paharganj, New Delhi-110055 (Appellant) (Respondent) Pan No. Aaacd3430G Assessee By : Sh. Jagdish Ajmani, Ca Revenue By : Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing: 26.06.2025 Date Of Pronouncement: 26.06.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023-254/1059410133(1) Dated 05.01.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Jagdish Ajmani, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 115BSection 143(3)Section 68

that the Revenue’s sole substantive grievance canvassed in the instant appeal seeks to revive the Assessing Officer’s action making section 68 unexplained cash credits addition of Rs.1,12,48,800/-; in the course of assessment dated 27.12.2019 and reversed in the 2 Dandona Finance Ltd. CIT(A)/NFAC ... Rs.60 lacs in light of CBDT’s latest Circular No. 9/2024, dated 17.09.2024. The Revenue quotes section 115BBE of the Act that such unexplained cash credits are infact assessed at higher rate from A.Y. 2017-18 onwards. 4. We find no merit in the Revenue’s instant clarification

Thota Raghu Buchanna, Hyderabad vs. Income Tax Officer, Ward 15(2), Hyderabad

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

ITA 542/HYD/2025[2014-15]Status: DisposedITAT Hyderabad25 Jun 2025AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.542/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2014-15) Thota Raghu Buchanna Vs. Income Tax Officer Hyderabad Ward-15(2) [Pan :Aftpt6248K] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Vinod, Ar रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Dr सुिवधई की तधरीख/Date Of Hearing: 24/06/2025 घोर्णध की तधरीख/Date Of 25/06/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.01.2025 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2014-15. 2. The Brief Facts Of The Case Are That The Assessee Had Filed His Original Return Of Income For The A.Y.2014-15 On 22.12.2014, Declaring Total Income Of Rs.9,93,210/-. The Assessment Has Been Subsequently Reopened U/S 147 Of The Income Tax Act, 1961 (“The Act”) On The Ground That As Per

For Appellant: Shri P.Vinod, ARFor Respondent: Shri Gurpreet Singh, DR
Section 131Section 144Section 147Section 148Section 68

determined the total income at Rs.52,44,195/- by making additions of Rs.42,50,985/- u/s 68 of the Act as unexplained cash credits. 3. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee neither appeared nor filed

ITO, Ward-1(1), Faridabad vs. Chaman, Faridabad

In the result, appeal of the assessee is allowed

ITA 2774/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Chaman, Income Tax Officer, Ward-1(1), H. No. 437, Sector-9, Faridabad Faridabad Pan: Bfapd6698P (Appellant) (Respondent) With C.O. No.103/Del/2024 [Arising Out Of Ita No.2774/Del/2024] Assessment Year: 2017-18 Vs. Income Tax Officer, Chaman, H. No. 437, Sector-9, Ward-1(1), Faridabad, Haryana Faridabad Pan: Bfapd6698P (Appellant) (Respondent) Assessee By Sh. Gaurav, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No. 2774/Del/2024 & Assessee’S Cross Objection C.O. No. 103/Del/2024 For Assessment Year 2017- 18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The

Section 147Section 250(4)

come in the appeal before the tribunal inter alia seeking to reverse the lower appellate findings deleting land acquisition compensation addition and unexplained cash credit entries as per its above substantive grounds raised in the instant appeal. 5. We have given our thoughtful consideration to the department ... Revenue’s instant former twin substantive grounds stand rejected therefore. 7. Next comes the latter issues between the parties regarding correctness of unexplained cash credit addition of Rs.9,53,608/-. The department could hardly dispute that the learned CIT(A)’s corresponding above extracted detailed discussion which has already considered