← 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

Prakash Jewellers, Mumbai vs. ACIT 32(2), Mumbai Bandra

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

ITA 6850/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2017-18 Prakash Jewellers, Acit 32 (2) 31 B-1 2Nd Floor, Meghdoot, S V Room No. 720, 7Th Floor, Road, Borivli West, Mumbai, Kautilya Bhavan C-41 To C- Vs. Maharashtra – 400092 43 G Block Bandra East, Mumbai, Maharashtra Pan : Aaafp4374Q 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Bhupendra Shah, Ld. A.R. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 17.12.2025 Date Of Pronouncement : 22.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 08.10.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2017-18. 2. In The Instant Case, The Assessing Officer Vide Assessment Order Dated 30.12.2019 Has Made An Addition Of Rs. 5,90,00,000/- Being Cash Deposited, In Yes Bank By The 2 Prakash Jewellers Assessee During The Demonetization Period, As Unexplained Cash Credit Under Section 68 Of The Act.

For Appellant: Shri Bhupendra Shah, Ld. A.RFor Respondent: Shri Virabhadra Mahajan, SR. D.R
Section 142(1)Section 250Section 68

being cash deposited, in Yes Bank by the 2 PRAKASH JEWELLERS Assessee during the demonetization period, as unexplained cash credit under Section 68 of the Act. 3. The Assessee being aggrieved against the said addition/ the Assessment Order preferred first Appeal before the Ld. Commissioner. 4. The Ld. Commissioner though

Multi Venture Infotech Pvt Ltd, Mumbai vs. National Faceless Appeal Centre, New Delhi

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

ITA 3677/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Jan 2026AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2014-15 Multi Venture Infotech Pvt. National Faceless Appeal Ltd., Centre 404 Bldg No. 8A Damodar Park, National Faceless Appeal Vs. Ghatkopar West, Mumbai, Centre, 245-A, North Block, Maharashtra – 400086 New Delhi, Delhi - 110001 Pan : Aaacm9718L (Appellant) (Respondent) Present For: Assessee By : Shri Tejas Sodha, Ld. A.R. Revenue By : Shri Virabhadra S. Mahajan, Sr.D.R. Date Of Hearing : 17.12.2025 Date Of Pronouncement : 22.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 12.04.2023, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac) /Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2014-15. 2. In The Instant Case, The Assessing Officer Vide Assessment Order Dated 24.05.2023 Under Section 147 R.W.S. 144 (B) Of The Act Has Made The Additions / Disallowances Of Rs. 2,03,00,000/- & Rs. 96,11,642/- Respectively On Account Of Unexplained Cash Credit Under Section 68 Of The Act & 2 Multi Venture Infotech Pvt. Ltd. Disallowance Of Loss In Derivative Transaction (Variation Proposed).

For Appellant: Shri Tejas Sodha, Ld. A.RFor Respondent: Shri Virabhadra S. Mahajan, SR.D.R
Section 147Section 250Section 68

made the additions / disallowances of Rs. 2,03,00,000/- and Rs. 96,11,642/- respectively on account of unexplained cash credit under Section 68 of the Act and 2 Multi Venture Infotech Pvt. Ltd. disallowance of loss in derivative transaction (variation proposed). 3. The Assessee filed first appeal before