“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

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7067/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

wherein two additions/disallowances were made, (1) disallowance of bogus purchases of ₹ 130,068,426/– and (2) addition under section 68 on account of unexplained cash credit of ₹ 20,616,167/–. 14. In similar manner, following additions or disallowances were made for other assessment years:- serial Assessment year Addition on account

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7066/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

DCIT 3(1)(1), Mumbai vs. Relcon Infraprojects Ltd, Mumbai

ITA 7065/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7064/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Jan 2026AY 2014-15

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

Zany Share Trading Pvt Ltd, Mumbai vs. Income Tax Officer, WD-8(3)(4), Mumbai

Accordingly, the grounds raised by the assessee stands partly allowed

ITA 4991/MUM/2025[2010-11]Status: DisposedITAT Mumbai19 Jan 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(1)Section 147Section 148Section 250Section 68

transactions to the extent of Rs. 1,41,68,000/- and therefore,the addition made by the AO is treating the same as unexplained cash credit is upheld.The appellant relied on numerous case laws in which the facts are different from the instant case.Thus, the ground nos.2

Harshish Singh, Delhi vs. ITO Ward 28(8), Delhi

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

ITA 6388/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] Harshish Singh, Income Tax Officer, 51 Basement, M. B. Road, Ward-28(8), Sainik Farms, Vs New Delhi New Delhi-110024 Pan-Avxps3485K Assessee Revenue Assessee By Shri Alok Yadav, Adv. Ms. Ameesha Malhotra, Adv. Revenue By Ms. Amish S Gupt, Cit-Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 19.01.2026

Section 115BSection 139Section 143(3)Section 44ASection 68

account of advance credit received from sundry creditors as well as advances from customers of Rs.6,31,950/- of the Act as unexplained cash credit. In appeal, the ld. CIT(A) confirmed the addition under section 68 made by the ld. Assessing Officer. 3. Per Contra, Ms. Amish S Gupt

Lal Babu Prasad, Siwan vs. ACIT, Circle-2, Muzaffarpur

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

ITA 317/PAT/2025[2015-16]Status: DisposedITAT Patna16 Jan 2026AY 2015-16

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 133ASection 250Section 43B

noticed that trade creditors amounting to ₹5,06,766 were outstanding. Since the assessee failed to verify ₹24,73,594 was treated as unexplained cash credit and added to the total income. 5. The Assessing Officer also noticed unrecorded purchases amounting to ₹9,59,500 based on comparison of purchase

Ghamanda Ram, Mandi vs. Income Tax Officer, Ward Mandi

In the result, appeal of the assessee is allowed

ITA 1334/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh16 Jan 2026AY 2017-18

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Atul Goyal, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr. DR

Section 148Section 44ASection 68

erred in confirming the addition of Rs.15,35,900/- which was added by the AO u/s 68 of the Act on account of unexplained cash credit. 4. With the assistance of ld. DR, we have gone through the record carefully. It emerges out from the record that assessee has filed ... return filed u/s 148. This difference was of Rs.18,25,327/-. Hence, he treated a sum of Rs.15,35,900/- as unexplained cash credit. 5. On due consideration of the above facts, we are of the view that once it has been accepted by the AO that assessee is trading

ITO Ward -2(1), Koolkata vs. Unicorn Land Developers Pvt Ltd, Kolkata

In the result, CO and the appeal of the Revenue are dismissed

ITA 688/KOL/2025[2012-13]Status: DisposedITAT Kolkata16 Jan 2026AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 1Section 131Section 132Section 132(1)Section 139(1)Section 143(3)Section 153ASection 68

issue against the deletion of 21,15,00,000/- by the Id. CIT (A) as made by the Id. AO on account of unexplained cash credit u/s 68 of the Act on the basis of seized documents with ID Mark UPPL/3, being incriminating material. The assessee has filed cross objection ... subscribers and genuineness of the transactions. However, the summons was not complied with. Finally, the Id. AO added the said amount as unexplained cash credit to the income of the assessee. Page |3 ITA No. 688/KOL/2025 & CO No. 51/KOL/2025 Unicorn Land Developers Pvt. Ltd.; A.Y. 2012-13 In the appellate

Sudheer Chirania, Mumbai vs. The Income Tax Officer, Ward - 23(3)(7), Mumbai

In the result, the appeal filed by the assessee partly allowed

ITA 5263/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Jan 2026AY 2012-13

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2012-13

For Appellant: Ms. Simran Dhawan & Mr. RaviFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 68Section 69C

shares of M/s Tilak Venture Limited, alleged to be a penny stock. The AO treated the LTCG of ₹2,20,36,564/- as unexplained cash credit under section 68 and further made an ad-hoc addition of ₹4,40,731/- under section 69C towards alleged commission expenses

Onus Plantations and Agro Limited, Delhi vs. DCIT, Central Circle-6, Delhi

In the result, appeal of the assessee is allowed

ITA 5004/DEL/2025[2015-16]Status: DisposedITAT Delhi16 Jan 2026AY 2015-16

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 127(2)(a)Section 127(3)Section 132Section 132(4)Section 139Section 153CSection 153DSection 250Section 68Section 69C

grossly erred in law and in facts of the case in assessing repaid loan of Rs. 22,00,000/- as unexplained cash credit u/s 68 of the Act. 6. That the Ld. AO grossly erred in law and in facts of the case in assessing loan ... unexplained cash credit u/s 68 of the Act despite discharge of onus cast upon assessee to substantiate genuineness of the same. 7. That the Ld. AO grossly erred in law and in facts of the case in making addition of Rs. 66,000/- u/s 69C of the Act. 8. That

Satish Kumar Mailik, New Delhi vs. ITO Ward 52(3), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 4307/DEL/2025[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalsatish Kumar Malik, Income Tax Officer, 2/31, Ansari Road, Darya Ganj, Ward-52(3), New Delhi-110002. Vs. Delhi. Pan-Adrpm7097D (Appellant) (Respondent) Assessee By Shri R.M. Mehta, Ca & Shri J.P. Chawla, Ca Department By Shri Jitender Singh, Cit-Dr Date Of Hearing 24/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 28.05.2025 In Appeal No. Cit(A), Delhi-18/10299/2019-20 Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’ In Short) Dated 30.12.2019 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Of Trading Of Goods. The Return Of Income For The Year Under Appeal Was Filed On 02.11.2017 Declaring Total Income Of Rs.26,19,530/- & The Case Of The Assessee Was Selected Under Complete Scrutiny Under Cass For The Reason “Abnormal Increase In Cash Deposit During The Demonetization”. Thereafter, Notice U/S 143(2) Satish Kumar Malik Vs. Ito Followed By Notices U/S 142(1) Were Issued From Time To Time, In Response To Which Assessee Filed Written Submissions. After Considering The Submissions Filed By The Assessee The Ao Was Of The Opinion That Assessee Had Deposited Cash Of Rs.44,44,750/- In Bank During Demonetization Period In Sbn Source Of Which Was Not Explained And, Therefore, Made The Addition Of The Said Cash As Unexplained Credits U/S 68 Of The Act & Further Invoked The Provisions Of Section 115Bbe Of The Act & Charge Tax At The Higher Rate.

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 145(3)Section 68

read with section 115BBE of the Income Tax Act, 1961, by treating the cash deposited in the bank during the demonetization period as unexplained cash credit, despite the fact that the entire amount was duly recorded in the regular books of accounts and supported by documentary evidence. 2. That

Gandaram and Sons Jewellers Pvt Ltd, Delhi vs. Ac Circle 10(1), New Delhi

In the result, appeal of the assessee in ITA No

ITA 3754/DEL/2025[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Karnik Rajat, AdvFor Respondent: Ms. Harpreet Kaur Hansra , Sr. DR

Section 115BSection 68

after giving credit of Rs. 53,32,920/- declared under the Income Declaration Scheme, 2016), was considered unexplained cash credit during demonetization period and added under section 68 of the Act. 5. Aggrieved, the assessee preferred an appeal before the CIT(A) who considering the facts and circumstances, upheld

Atma Ram Builders Private Limited, New Delhi vs. Income Tax Officer, Central Circle 5, New Delhi

In the result, appeal of the Assessee is allowed in above terms

ITA 3593/DEL/2025[A.Y. 2020-21]Status: DisposedITAT Delhi16 Jan 2026

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 143(3)Section 263Section 269TSection 270ASection 271ESection 69ASection 80G

cash deposit unexplained amount of Rs. 1,50,405/-. The AO therefore, proposed the 3 Atma Ram Builders Pvt. Ltd. variations unexplained cash credit of Rs. 1,50,405/- and disallowance of interest expenses of Rs. 10,48,480/- and total variations proposed was Rs. 11,98,885/-. With respect

Horizon Buildmart Pvt Ltd, Gurgaon vs. ACIT, Circle-2, Faridabad

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

ITA 1250/DEL/2025[2011-12]Status: DisposedITAT Delhi16 Jan 2026AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalhorizon Buildmart Pvt. Ltd., Asst. Cit, C-131, Ground Floor, Block-C, Central Circle-Ii, Sushant Shopping Arcade, Vs. Faridabad, Sushant Lok-1, Haryana-121001. Gurgaon-122002. Pan-Aacch4582P (Appellant) (Respondent) Shri S.S. Nagar, Ca Assessee By Department By Ms. Amisha S. Gupta, Cit Dr Date Of Hearing 03/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon (‘Ld. Cit(A)’ In Short) Dated 27.01.2025 In Appeal No.10581/Cit(A) Ggn-3/2018-19 For Assessment Year 2011-12 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (‘The Act’ For Short) Dated 28.12.2018. 2. Brief Facts Of The Case Are That Assessee Is Private Limited Company Engaged In The Business Of Real Estate. The Assessee Filed Its Return Of Income On 30.09.2011 Declaring A Loss Of Rs.54,833/-. The Ao Had Information That Assessee Received Loan Horizon Buildmart Pvt. Ltd. Vs. Acit

Section 143(2)Section 147Section 148Section 153C

alleged that M/s Grand Realcon Private Limited is a paper company established to provide accommodation entries the loan taken from it is unexplained cash credit us/ 68 of the Act and made the addition of Rs.8.35 towards loan received by the assessee from M/s Grand Realcon Pvt. Ltd. 3. Against

Assistant Commissioner of Income Tax, New Delhi vs. Jalco Financial Services Private Limited, New Delhi

The appeal is dismissed

ITA 4209/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveenc Chandraacit, Vs. Jalco Financial Services Room No. 316A, C.R. Private Limited Building, I.P. Estate, K-7B, Ground Floor, New Delhi – 110002 Kalkaji, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacj2791E Appellant .. Respondent

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. Om Prakash, Sr. DR

Section 143(1)Section 143(3)Section 15HSection 37Section 37(1)Section 68

submissions of the assessee did not appeal to the AO and addition of Rs.5,16,00,000/- was made on account of unexplained cash credit under Section 68 of the Act and by disallowing the amount of Rs.10,00,000/- on account of expenditure claimed by the assessee under Section ... case and in law, the ld. CIT(A)/NFAC has erred in deleting the addition of Rs.5,16,00,000/- on account of unexplained cash credit u/s 68 of the Act. The appellant craves to add, alter or amend any/ all of the grounds of appeal before or during

Zia Rathi, Delhi vs. Income Tax Officer Ward-44(3), Delhi

In the result, appeal filed by the assessee is allowed

ITA 1881/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalmrs. Zia Rathi, Income Tax Officer, 274, Dda Flats, Sector-1A, Ward-44(3), Dwarka Nasirpur, Vs. Delhi. New Delhi-110045. Pan-Bsvpr9218M (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. Shri Saksham Agarwal, Ca & Shri Deepesh Garg, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 04/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 27.02.2024 In Appeal No. Cit(A), Delhi- 15/11146/2019-20 Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’ For Short) For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is Sole Proprietor Of M/S Veezee Traders Engaged In The Business Of Trading Of Pvc Coated Imported Fabric. The Zia Rathi Vs. Ito

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 234BSection 68

Mohan Kukreja concluded that the cash deposited in the bank account in SBN during demonetization period of Rs. 2,23,46,000/- is unexplained cash credit and made the addition for the same on protective basis in the hands of assessee by observing that this cash was actually hold

ACIT, Circle-10(1), New Delhi vs. Index Securities & Research Pvt Ltd, New Delhi

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

ITA 2181/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68

operation conducted in case of Jagat Group, assessments were completed in assessment years 200708, 2008-09 an 2009-10 making huge additions towards unexplained cash credit under section 68 of the Act by treating the share application money and share premium as bogus. While deciding the appeals of the assessee ... Rs.9,73,37,500/- qua AY 2009-10, by treating the bogus share application money/share premium as unexplained cash credit?" 20. Undisputedly, the assessee company has supplied confirmation letter from the share applicants; copies of bank accounts of a day or week of the share applicants; copy of acknowledgement

Prem Lata Verma, Aligarh, Uttar Pradesh vs. DCIT, Circle 4(1)(1), Aligarh, Uttar Pradesh

In the result, assessee’s appeal is allowed

ITA 441/AGR/2025[2016-17]Status: DisposedITAT Agra15 Jan 2026AY 2016-17

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2016-17

Section 10(1)Section 139Section 144Section 147Section 148Section 234BSection 250Section 271(1)(c)Section 68

section 68 of the Act, by treating the loan advanced to M/s Raj Prem Associates (P.) Ltd. during the year under consideration as unexplained cash credits. 3. Ground No. 3: That the Ld. CIT(A) has erred in law as well as on facts by upholding the addition

Lokendra Kumar Gautam, Mathura vs. ITO Ward, 1(3)(2), Mathura

In the result, assessee’s appeal is allowed

ITA 335/AGR/2025[2017-18]Status: DisposedITAT Agra15 Jan 2026AY 2017-18

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2017-18

Section 143(3)Section 250Section 68

assessee’s business was closed on 31.10.2016. The Assessing Officer rejected the explanation of the assessee and treated the entire cash deposit as unexplained cash credit under section 68 of the Act, and made addition of Rs.1,24,00,000/- u/s. 68 of the Act, vide assessment order dated ... Income-tax Act, 1961 is legally unsustainable, as cash deposits arising out of explained and disclosed withdrawals cannot be treated as unexplained cash credits. The Learned AR further submitted that an amount of Rs.1,00,000/- was deposited during the demonetization period in the assessee’s savings bank account with