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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

Ankit Jain, Hyderabad vs. ACIT., Central Circle - 1(2), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1544/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jan 2026AY 2019-20

Bench: Us:

Section 115BSection 143(3)Section 147Section 148Section 148ASection 292CSection 69

following grounds of appeal before us: “1. The Learned First Appellate Authority, is not justified in conforming addition of Rs.7.44,800/- as unexplained cash credit u/s. 69 made by the Ld. Assessing Officer 2. a) The Learned First Appellate Authority, in the facts and circumstances of the case

DCIT., Circle-3(1), Hyderabad vs. South Asian Ceramic Tiles Private Limited, Hyderabad

ITA 1228/HYD/2025[2022-23]Status: DisposedITAT Hyderabad30 Jan 2026AY 2022-23
Section 143(2)Section 143(3)Section 68Section 69

only, therefore, the AO was constrained to treat the balance amount of the unsecured loans of Rs.3,17,26,261/- as unexplained cash credits under section 68 of the Act. 5. Apart from that, the AO observed that the assessee company had during the subject year made investments in tangible ... Rs.62,62,96,168/-) could not be 5 DCIT vs. South Asian Ceramic Tiles Pvt Ltd verified, therefore, he held the same as unexplained cash credits under section 68 of the Act. The AO based on his aforesaid observations determined the income of the assessee company at Rs.35

H R Infracon Limited, Howrah vs. DCIT, Circle 7(1), Kolkata

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

ITA 2835/KOL/2025[2022-2023]Status: DisposedITAT Kolkata30 Jan 2026AY 2022-2023

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 250Section 68

bogus or ingenuine. 2.3 That the Ld. CIT(A) failed to appreciate that Section 68 of the Income Tax Act, 1961 applies to unexplained cash credits and not to trade payables or liabilities which are duly recorded in the books of account 2.4 That the Ld. CIT(A) erred

Tara Hospitality Pvt Ltd, Office No A vs. Income Tax Officer 15(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 7445/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokartara Hospitality Private Vs Income Tax Officer 15(3)(1), Limited Mumbai Office No.A-112 Plot No.53, Room No.456 Aayakar Bhawan, Sector-15Cbd Belapur Navi M.K. Road, Mumbai-400020 Mumbai-400614 Pan:Aaect7774K Appellant Respondent Assessee By : Shri Satyaprakash Singh, Ca Respondent By : Shri Ritesh Misra (Cit Dr) Date Of Hearing : 28/01/2026 Date Of Pronouncement : 30/01/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Nfac, Delhi (For Brevity ‘The Ld. Cit(A), Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2018-19, Date Of Order 19.09.2025. The Impugned Order Emanated From The Order Of The National Eassessment Centre, Delhi (For Brevity The “Ld. Ao”), Order Passed Under Section 144 R.W.S. 144B Of The Act Date Of Order 23.04.2021. 2 Tara Hospitality Pvt. Ltd. 2. We Heard The Rival Submission & Considered The Documents Available In The Record. The Assessee Company Filed The Return By Admitting Loss Amount Of Rs.6,85,303/-. The Assessment Proceeding Was Initiated. During The Assessment Ld. Ao Found In Column No.31(A) Of The Audit Report For Form No.3Cd That Assessee Has Taken Loan From Three Different Parties Amount Of Rs.1,45,75,891/-. But Finally The Assessment Order Was Passed Ex Parte & The Unsecured Loan Amount Of Rs.1,45,75,891/- Was Added Back As Unexplained Cash Credit U/Sec. 68 Of The Act. Aggrieved Assessee Filed An Appeal Before The Ld. Cit(A). The Ld. Cit(A) Passed An Order Ex Parte & Uphold The Impugned Assessment Order. Being Aggrieved Assessee Filed An Appeal Before Us.

For Appellant: Shri Satyaprakash Singh, CAFor Respondent: Shri Ritesh Misra (CIT DR)
Section 144Section 250Section 68

finally the assessment order was passed ex parte and the unsecured loan amount of Rs.1,45,75,891/- was added back as unexplained cash credit u/sec. 68 of the Act. Aggrieved assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A) passed an order ex parte

Niket Sohanlal Jain, Mumbai vs. Income Tax Officer Ward20(2)(1), Mumbai

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

ITA 6775/MUM/2025[2021-22]Status: DisposedITAT Mumbai30 Jan 2026AY 2021-22

Bench: Shri Om Prakash Kant, Jm & Ms. Kavitha Rajagopal, Am Mr. Niket Sohanlal Jain, Officer-In-Charge (Nfac), Delhi Room No.35, Ahmed Sailor Building Current Jurisdiction: No.5, Income Tax Officer, Sadanad Jadhav Marg, Vs. Ward 20(2)(1), Opp. Dakre Guruji Garden, Mumbai – 400012 Naigaon, Mumbai – 400 014 Pan: Badpj0703R (Appellant) : (Respondent)

For Appellant: Mr. Dalzin Madan, C.A. &For Respondent: Shri S. Srinivasu, CIT DR
Section 143(2)Section 250Section 37Section 68Section 69C

confirming the action of the learned Assessing Officer in making additions amounting to Rs. 12,43,66,969/- on account of alleged unexplained cash credit being sundry creditors u/s. 68 of the I.T. Act, 1961. 3. On the facts and circumstances of the case as well

Gnana Kathir Singarayar, Mumbai vs. ITO, Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 5502/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankargnana Kathir Singarayar, V/S. Income Tax Officer, Piramal Room No.1, Row N Block बनाम Chambers, Lalbaug, Mumbai No. 12, Transit Camp, - 400012, Maharashtra Dharavi, Mumbai - 400 017, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Apyps5634M Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Shri Swapnil Choudhary (Sr. AR)
Section 115BSection 143(2)Section 143(3)Section 144

demonetization period. As per the provisions of the Act, onus was on the assessee to explain the nature and source of any unexplained cash credits or investments. The AO provided ample opportunities to the appellant to furnish explanations and supporting evidence through multiple notices issued under sections

Aeon Commercial India Private Limited, Mumbai vs. The Assistant Commissioner of Income Tax Circle 15(1)(1), Mumbai, Mumabi

In the result, the appeal of the assessee is allowed on

ITA 5381/MUM/2025[2020-2021]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-2021

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 151Section 270ASection 68

transactions were accommodation entries in the garb of unsecured loans. Accordingly, he treated the sum of Rs. 1,18,69,619/- as unexplained cash credit under section 68 of the Act and added the same to the total income. The assessed income was determined ... Assessing Officer on account of amount credited in the books of accounts, treated as accommodation entry in the form of fictitious loan as unexplained cash credits under section 68 of the Income Tax Act, 1961 to applied the taxed under the provision of section 115BBE of the Income

Jay Hansraj Chheda, Mumbai vs. Income Tax Officer Ward 19(2)(1), Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2656/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Jan 2026AY 2015-16

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Prabhash Shankar, Am Mr. Jay Hansraj Chheda Income Tax Officer Ward 19(2)(1) Room No. 61, 4Th Floor, Vasant Villa, Matru Mandir, Room No. 221, Behnama Hall Lane, Prarthna Samaj, Vs. Tardeo Road, Mumbai – 400007. Mumbai – 400006. Pan/Gir No. Ajlpc9910H (Assessee) (Respondent) : Income Tax Officer Jay Hansraj Chheda Room No. 61, 4Th Floor, Vasant Room No. 502, Piramal Chamber, Lalbaug, Parel, Mumbai – 400012. Vs. Villa, Behnama Hall Lane, Prarthna Samaj, Mumbai – 400006. Pan/Gir No. Ajlpc9910H (Assessee) : (Respondent)

For Appellant: Shri. Manoj Pandit
Section 10(38)Section 143(2)Section 143(3)Section 250Section 68Section 69Section 69C

deposited in respondent‟s bank account. In view thereof, the CIT(A) found there was no reason to add the capital gains as unexplained cash credit under section 68 of the Act. The Tribunal while dismissing the appeals filed by the Revenue also observed on facts that these shares were

Gargi Overseas Pvt Ltd, Delhi vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 91/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumargargi Overseas Pvt. Ltd, Vs. Income Tax Officer, 2623-A, Naya Bazar, Delhi Ward-10(1), Delhi (Appellant) (Respondent) Pan: Aaacg3165F

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 133ASection 147Section 148Section 148ASection 68Section 69C

sales made by assessee to M/s. Kalki Trading Company in the sum of Rs. 11,17,38,184/- and adding the same as unexplained cash credit u/s 68 of the Act in the facts and circumstances of the instant case. 3. We have heard the rival submissions and perused ... assessee to M/s. Kalki Trading Company in the sum of ₹11,17,38,184/- which was sought to be treated as unexplained cash credit u/s 68 of the Act by the lower authorities. 7. At the outset, we find that purchases made by the assessee from two suppliers

Seema Puri, Haryana vs. ITO, Ward-59(1), Delhi

ITA 7591/DEL/2025[2011-12]Status: DisposedITAT Delhi30 Jan 2026AY 2011-12

Bench: Shri C.N. Prasad

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘SMC’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER ITA No.7591/Del/2025 [Assessment

Income Tax Officer, Delhi vs. Swan Digital Foundation, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3108/DEL/2025[2012]Status: DisposedITAT Delhi30 Jan 2026

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 147Section 148Section 25Section 68

Shujaat Hussain. Accordingly, the AO treated the receipts in the hands of the assessee amounting to Rs.1,23,85,000/- as unexplained cash credit u/s 68 of the Act as the assessee failed to establish the source to the satisfaction of the AO. Accordingly, the AO completed the assessment proceedings

Deputy Commissioner of Income, Central Circle, Meerut vs. Dr. Jagat Narain Subharati Charitable Trust, Dehradun

ITA 2553/DEL/2024[2013-14]Status: DisposedITAT Delhi30 Jan 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr
Section 143(3)Section 148Section 68

addition of Rs.7,25,00,000/- made by the Assessing Officer by treating the unsecured loans of Rs. 7,25,00,000/- as unexplained cash credits u/s 68 ofthe course LT. Act, 1961, without appreciating the fact brought on record by the AO during the course of assessment proceedings

Deputy Commissioner of Income Tax, Central Circle, Meerut, Income Tax Office vs. Dr. Jagar Narain Subharti Charitable Trust, Dehradun

ITA 2552/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Jan 2026AY 2012-13

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr
Section 143(3)Section 148Section 68

addition of Rs.7,25,00,000/- made by the Assessing Officer by treating the unsecured loans of Rs. 7,25,00,000/- as unexplained cash credits u/s 68 ofthe course LT. Act, 1961, without appreciating the fact brought on record by the AO during the course of assessment proceedings

Ashvin Dineshbhai Jadav, Rajkot vs. ITO, Ward-1(1)(1), Rajkot

In the result, the appeal of the assessee is allowed

ITA 428/RJT/2025[2015-16]Status: DisposedITAT Rajkot29 Jan 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 133(6)Section 143(2)Section 143(3)Section 250

furnished by assessee. All grounds raised by the assessee are against the addition of Rs.41,64,500/- u/s 68 of the Act as unexplained cash credit. There is only one issue to be decided, whether the assessee is able to explain the source of cash deposits. The assessee is working ... portion of depreciation) Same was allowed - Principal Commissioner invoked revision under section 263 on ground that assessee's income included deemed income being unexplained cash credit under section 68 which is not classified under any heads of income under section 14 therefore, set off of brought forward loss against this

Mohammad Zaki, Allhabad vs. Income Tax Officer, Ward-1(3), Allahabad

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

ITA 81/ALLD/2025[2011-12]Status: DisposedITAT Allahabad29 Jan 2026AY 2011-12

Bench: Shri Anadee Nath Misshra

Section 147Section 250(6)

short) determining the total income of the assessee at Rs.19,10,570/- by making addition of Rs.14,47,148/- on account of unexplained cash credit. Being aggrieved, the assessee filed appeal against the assessment order in the I.T.A. No.81/Alld/2025 Assessment Year:2011-12 2 office of learned CIT(A). Vide

Ankit Vijaykumar Jain, Ahmedabad vs. The Dy.CIT, Circle-3(2), Ahmedabad

In the result, both the appeals of the Revenue are dismissed

ITA 1565/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri D K Parikh, A.RFor Respondent: Shri Kamal Deep Singh, Sr. DR
Section 115BSection 271ASection 68

explained withdrawals, and that once sales were accepted and taxed in the profit and loss account, treating the same receipts again as unexplained cash credit would result in double taxation. The assessee relied upon several judicial precedents including decisions Ankit Vijaykumar Jain vs. DCIT Asst.Year ... regular books of account and such sales are not found to be fictitious, the same receipts cannot again be brought to tax as unexplained cash credits, as it would amount to double taxation of the same income. In this context, reliance placed by the learned counsel for the assessee

Ohm Developers, Sabarkantha vs. The ACIT, Circle, Himatnagar

In the result, the appeal of the assessee is dismissed

ITA 1538/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalohm Developers The Acit, Circle Vs. C/O. Bhandari Marketing Income Tax Office 1, Manish Market Himatnagar – 395 001 Nr. Old State Bank Nava Bazar, Himatnagar – 383 001 (Sabarkantha Dist.) [Pan : Aacfo 2907 N] (Appellant) .. (Respondent) Assessee Represented By : Shri Tej Shah, Advocate Revenue Represented By : Shri Abhijit, Sr.Dr 27/11/2025 Date Of Hearing Date Of Pronouncement 29/01/2026

Section 143(3)Section 271ASection 68Section 69A

during the demonetization period. On these facts, the Assessing Officer treated the cash deposits to the extent of Rs.1,72,83,364/- as unexplained cash credits under section 68 of the Act and added the same to the total income. 5. Aggrieved by the assessment order, the assessee filed ... primary grounds were that the Assessing Officer erred in computing the total income by making an addition of Rs.1,72,83,364/- as unexplained cash credit, that the addition was wrongly made under section 68 instead of section 69A of the Act, that interest under sections 234A/B/C/D was wrongly charged

Gunai Shikshan Prasarak Mandal, Udgir vs. Deputy Commissioner of Income-Tax, Aurangabad

In the result, the appeal filed by the assessee in ITA

ITA 1421/PUN/2025[2017-18]Status: DisposedITAT Pune29 Jan 2026AY 2017-18

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Tanaji Chavan
Section 115BSection 143(3)Section 68

115BBC of the Act and also made an addition of the above said cash deposits amounting to Rs.80,18,423/- as unexplained cash credits u/s 68 of the Act to the total income of the appellant. 3. Being aggrieved with the above assessment order, the assessee preferred an appeal before ... cash deposits during the demonetization period, the AO has made an addition amounting to Rs.80,18,423/- u/s 68 of the Act as unexplained cash credit to the total income of the appellant. 6.2 Ground No.1 – Addition u/s 115BBC of the Act - Rs.2,12,84,180/- 6.2.1 It is observed

Deputy Commissioner of Income Tax, Exemptions Circle, Aurangabad vs. Gunai Shikshan Prasarak Mandal, Latur

In the result, the appeal filed by the assessee in ITA

ITA 1370/PUN/2025[2017-18]Status: DisposedITAT Pune29 Jan 2026AY 2017-18

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Tanaji Chavan
Section 115BSection 143(3)Section 68

115BBC of the Act and also made an addition of the above said cash deposits amounting to Rs.80,18,423/- as unexplained cash credits u/s 68 of the Act to the total income of the appellant. 3. Being aggrieved with the above assessment order, the assessee preferred an appeal before ... cash deposits during the demonetization period, the AO has made an addition amounting to Rs.80,18,423/- u/s 68 of the Act as unexplained cash credit to the total income of the appellant. 6.2 Ground No.1 – Addition u/s 115BBC of the Act - Rs.2,12,84,180/- 6.2.1 It is observed

Manackraj Kamaraj, Ambur vs. ITO, Non Corpate Ward 11(2), Chennai

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

ITA 2541/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Jan 2026AY 2017-18

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita No. 2541/Chny/2025 "नधा"रण वष"/Assessment Year: 2017-18 V. Manackraj Kamaraj Ito Ncw 11(2) No. 23/10, Ramar Koil Street, Chennai Ambur-635 802. Tamil Nadu [Pan: Alzpk 7476 Q] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 115BSection 143(3)Section 156Section 68

addition of Rs.25,69,251/- was made by treating Manackraj Kamaraj VS ITO NCW 11(2) Chennai :: 2 :: credit card payments as unexplained cash credits u/s. 68 of the Act, 1961. 2. The assessee is an individual engaged in running a chat and juice shop in the name and style ... Manackraj Kamaraj VS ITO NCW 11(2) Chennai :: 3 :: Assessing Officer, however, completed the assessment by treating the entire credit card payments as unexplained cash credits u/s.68, taxed the same u/s.115BBE, raised demand u/s. 156 amounting to Rs.27,87,686/-. 3. The ld. CIT(A) confirmed the addition, observing that