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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

Bhaumik Jewellers Private Limited, Ahmedabad vs. The ITO, Ward-1(1)(2), Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 1642/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1642/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Bhaumik Jewellers Private The Ito बनाम/ Limited Ward-1(1)(2) V/S. 111, Gold Souk Complex Ahmedabad B/H. Sapphire Complex Cg Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aagcb 2423 B (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 03/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac), Delhi [In Short “The Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 (In Short “The Act”), Dated 26/07/2024 Arising Out Of The Assessment Order Passed By The Assessing Officer (In Short “The Ao”) Under Section 143(3) Of The Act For The Assessment Year 2017-18. The Assessee In This Appeal Has Agitated The Confirmation Of The Addition Of Rs. 9,65,97,834/- Made By The Ao Under Section 68 Of The Act Bhaumik Jewellers Private Limited Vs. The Ito Asst. Year : 2017-18

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 115BSection 133(6)Section 143(3)Section 145(3)Section 250Section 68

account of the assessee under section 145(3) of the Act and treated the amount of Rs. 9,65,97,834/- as unexplained cash credits under section 68 of the Act read with section 115BBE of the Act, treating the same as income from undisclosed sources. 4. Aggrieved

Kishorbhai Dattani, Jam Khambhalia vs. Income Tax Officer, Ward -1, Dwarka

In the result, the appeal of the assessee is allowed

ITA 555/RJT/2025[2017-18]Status: DisposedITAT Rajkot02 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 555/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Kishorbhai Dattani Vs. Income Tax Office, Hospital C/O. Sarda & Sarda (Ca), Sakar 1St Road, Near Rajdhani Hotel, Floor, Dr. Radha-Krishnan Road, Dwarka, Gujarat 361335 Opp. Rajkumar College, Rajkot, Rajkot Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakpd7272M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 03 / 11 /2025 Date Of Pronouncement : 02/ 02 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR
Section 115BSection 144BSection 147Section 148Section 250Section 69A

assessee based on the documentary evidence during the proceedings. Accordingly, the learned CIT (A) treated the amount received from such parties as unexplained cash credit under section 68 of the Act. In this connection we note that the impugned amount has been taxed twice firstly the same was treated ... sales and secondly the same was treated as unexplained cash credit under section 68 of the Act. Even if we assume that the action of the learned CIT (A) is correct i.e. the impugned amount is representing the cash credit as provided under section 68 of the Act. Then

Dhwani Jayeshkumar Patel, Panchmahal vs. The ITO, Ward-4(1)(2), Vadodara

ITA 1757/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad02 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1757/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Dhwani Jayeshkumar Patel The Ito बनाम/ Pro. Of Jay Enterprise Ward-4(1)(2) V/S. 19-1, Neeta Nagar Society Vadodara 390 007 Kanjari Road Halol, Panchmahal 389 350 (Gujarat) "थायी लेखा सं./Pan: Bynpp 3496 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Sakar Sharma, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10 /11/2025 घोषणा की तारीख /Date Of Pronouncement: 02/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 25/07/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. In This Appeal, The Assessee Is Aggrieved By The Action Of The Ld. Cit(A) In Confirming The Addition Made By The Assessing Officer (Ao) Of Dhwani Jayeshkumar Patel Vs. The Ito Asst4.Year : 2017-18

For Appellant: Shri Sakar Sharma, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 131Section 133(6)Section 250

made by the Assessing Officer (AO) of Dhwani Jayeshkumar Patel vs. The ITO Asst4.Year : 2017-18 Rs.31,28,66,130/- on account of unexplained cash credits in the bank account of the assessee. 3. The brief facts of the case the AO on verification of bank accounts of the assessee