← 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

Charles Pyngrope, Shillong vs. ITO W-1 Shillong, Shillong

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

ITA 253/GTY/2025[2021-22]Status: DisposedITAT Guwahati13 Mar 2026AY 2021-22

Bench: Shriduvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Charles Pyngrope Ito, Ward-1 Hosanna Pohkseh, Umpling, P.S. Kharmalki Road, Shillong- Rynjah, Shillong-793006, Vs. 793001, Meghalaya Meghalaya (Appellant) (Respondent) Pan No. Ahfpp6810P Assessee By : Shri J.P. Gupta, Ar Revenue By : Shri Santosh Kumar Karnani, Dr Date Of Hearing: 12.03.2026 Date Of Pronouncement: 13.03.2026

For Appellant: Shri J.P. Gupta, ARFor Respondent: Shri Santosh Kumar Karnani, DR
Section 68

order of ld. CIT (A) confirming the order of the ld. AO wherein the addition of ₹34,52,17,052/- was made as unexplained cash credit u/s 68 of the Income-tax Act, 1961 (the Act) Charles Pyngrope; A.Y. 2021-22 and second, challenging the confirmation of addition ... unexplained cash credit u/s 68 of the Act by the ld. AO in respect of cash deposited. 3. The ld. Counsel for the assessee at the outset stated that there was no proper compliance before the ld. AO qua the money received for the land acquisition as well

Assistant Commissioner of Income-Tax, Aayakar Bhawan vs. Sushil Kumar Surana, Guwahati

In the result, appeal of the revenue stands dismissed

ITA 198/GTY/2024[2017-18]Status: DisposedITAT Guwahati13 Mar 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumarsushil Kumar Surana, A.C.I.T., C/O-Thansinghnathmal, A.T. Road, Circle-2, Vs. Opposite Apsara Cinema Hall, Guwahati. Guwahati-781001 (Assam) (Appellant) (Respondent) Pan No. Awdps 3148 J Revenue By : Shri Santosh Kumar Karnani, Addl. Cit Assessee By : Shri Ramesh Goenka, Advocate. Date Of Hearing: 11/03/2026 Date Of Pronouncement: 13/03/2026 O R D E R

For Appellant: Shri Ramesh Goenka, AdvocateFor Respondent: Shri Santosh Kumar Karnani, Addl
Section 68

admitting new evidences as made by the Assessing Officer under Section 68 of the Income Tax Act, 1961 (in short, the Act) as unexplained cash credit. 3. The facts of the case, in brief, are that the assessee filed return of income on 29/10/2017 declaring total income ... interest rate was 12%. The Assessing Officer finally treated the impugned loans by three loan creditors aggregating to ₹ 8,25,00,000/- as unexplained cash credit as the necessary ingredients of Section 68 of the Act were not specified and added to the income of the assessee

Dastagir Hamid Mujawar, Sangli vs. ITO Ward-2, Sangali

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

ITA 1851/PUN/2025[2017-18]Status: DisposedITAT Pune13 Mar 2026AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1851/Pun/2025 Assessment Year : 2017-18 Dastagir Hamid Mujawar, Vs. Income Tax Officer, Nath Galli, Near Mashedee, Ward-2, Sangli Vita At Post Vita, Tal. Khanapur, Sangli-415311 Maharashtra Pan : Awqpm0876L Appellant Respondent

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Basavaraj Hiremath
Section 143(1)Section 144Section 68

Indian Bank, Sangli Branch. In the absence of any submission from the side of assessee, Ld. Assessing Officer treated the said sum as unexplained cash credits and made addition u/s.68 of the Act. Income assessed at Rs.1,00,23,470/- as against the returned income of Rs.3

Dandeboina Ramesh, Warangal vs. ITO, Ward-(1), Warangal

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

ITA 1661/HYD/2025[2015-16]Status: DisposedITAT Hyderabad13 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Section 115Section 139Section 144Section 147Section 148Section 148ASection 149Section 69A

HTT HAAS HALT, SarTaTe HTS IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad aft ferore Wet Wa, SoTeaaT

Dugginnigari Subramaniyam Naidu, Tirupati vs. ACIT., Circle - 1(1), Tirupati

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

ITA 1443/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Bench: the Ld. AO.

Section 133(6)Section 68

rejected the explanation of the assessee and made addition of Rs. 1,69,75,626/- under section 68 of the Act, as unexplained cash credit and brought it to tax under section 115BBE of the Income Tax Act, 1961. 5. Aggrieved by the assessment order, the assessee preferred appeal before ... relevant details, the A.O. has rightly rejected the explanation of the assessee and assessed the cash deposits into the bank account as unexplained cash credit under section 68 of the Act. The relevant findings of the Ld. CIT(A) are as under: “6.12 I have considered the facts and circumstance

DCIT, Circle 2(1), Trichy Stationed at Thanjavur, Thanjavur vs. Sri Bhuvanesvari Thangamaligai, Pudukkottai

In the result, appeal filed by the Revenue is dismissed

ITA 2915/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Respondent: Ms.R. Anitha, Addl.CIT
Section 133ASection 68

assessee’s business income, it was unjustified on AO’s part to again assess the same by way of unexplained cash credit. Once, sales and purchases are duly recorded in books of accounts and the copy of sales register and purchase register were produced before AO and all transactions ... meaning of income and cash credit. Sales which the assessee has shown which AO has accepted as income, later was considering as unexplained cash credit clearly goes against the accounting principles and taxation law. The Ld.CIT(A) is noted to have appreciated the aforesaid facts and position

Ramesh Lalawat, Vashi Mumbai vs. Income Tax Officer Ward 28(2)(1), Navi Mumbai

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

ITA 8838/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Ramesh Lalawat Income Tax Officer, Room No 102, Goma Sadan Ward 28(2)(1), Plot No 400, Mumbai Nr Cisf, Juhu Gaon Vs. Sector No. 11, Vashi, Navi Mumbai - 400703 (Pan: Aeepl2218K) (Appellant) (Respondent) Present For: Assessee : Shri Ajay R. Singh, Advocate Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 09.03.2026 Date Of Pronouncement : 13.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1074653077(1), Dated 18.03.2025, Passed Against The Assessment Order By Mum-W-(272)(91), U/S. 147 R.W.S. 144 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 15.09.2023, For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under:

For Appellant: Shri Ajay R. Singh, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 147Section 249Section 249(2)Section 3Section 5

treating the cash deposit during the demonetization period as unexplained cash credit. 5. The CIT (A) failed to take the cognizance of the Income Tax Return (" ITR ") filed by the appellant which duly discloses the amount of cash deposited during the demonetization period. It is therefore prayed to your honour

Nathan Anil Rao, Mumbai vs. The ITO -Circle 23(1), Mumbai

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

ITA 8666/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Vijaykumar Soni, CIT DRFor Respondent: Shri Nikhil Tiwari
Section 143(2)Section 68Section 69

income after addition of 16,02,68 determining total income after addition of 16,02,68,952/- with respect to with respect to unexplained cash credit invoking section 68, is justified and in accordance with unexplained cash credit invoking section 68, is justified and in accordance with unexplained cash credit

Namah Shivaya Marketing Private Limited, Delhi vs. Income Tax Officer, Ward 18(1), Delhi

In the result, the appeal filed by the Assessee is allowed

ITA 6011/DEL/2025[2008-09]Status: DisposedITAT Delhi13 Mar 2026AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarnamah Shivaya Marketing Income Tax Officer, Private Limited, Ward-18 (1), 206, Hans Bhawan, 1 Bahadur Vs. Delhi-110002. Shah Zafar Marg, Delhi-110002 . Pan-Aabcn7435Q (Appellant) (Respondent) Assessee By Shri Suresh Kumar Gupta, Ca Department By Shri Manish Gupta, Sr. Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 07.08.2025 Of The Learned Commissioner Of Income Tax (Appeals)-Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 28.11.2019 Of The Ld. Assessing Officer, Ward No.18(1), New Delhi [Hereinafter Referred As ‘The Ao’] U/S 143(3)/263 Of The Act For Assessment Year 2008-09. 2. Brief Facts Of The Case Are That Assessee Filed Return Declaring Total Income Of Rs.7,070/- On 09.07.2008. Assessment Order Dated 21.03.2016 Was Passed. Hon’Ble

Section 142(1)Section 143(3)Section 147Section 153CSection 250Section 68

circumstances of the cases in upholding the addition of Rs.30,00,000/- u/s 68 of the IT Act holding the share capital as unexplained cash credit ignoring the fact that the assessee has discharged its initial onus us 68 of the IT Act explaining nature and source of the credits ... submitted that Ld. CIT(A) erred in upholding addition of Rs.30,00,000/- u/s 68 of the Act holding the share capital as unexplained cash credit ignoring the fact that the assessee has discharged its initial onus u/s 68 of the Act explaining nature and source of the credits

Kunwar Pranav Singh Champion, Roorkee vs. Income Tax Officer, Roorkee

In the result, the captioned appeals of the assessee in ITA No

ITA 41/DDN/2026[2020-21]Status: DisposedITAT Dehradun12 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 250Section 271ASection 68

observed that the addition of INR 43.00 Lakhs was made u/s 68 of the Act on account of unexplained cash credit which was sustained for the reason that assessee has failed to file the details with respect to the agricultural income declared by him. Even before AO, no such details

Kunwar Pranav Singh Champion, Roorkee vs. Income Tax Officer, Roorkee

In the result, the captioned appeals of the assessee in ITA No

ITA 40/DDN/2026[2020-21]Status: DisposedITAT Dehradun12 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 250Section 271ASection 68

observed that the addition of INR 43.00 Lakhs was made u/s 68 of the Act on account of unexplained cash credit which was sustained for the reason that assessee has failed to file the details with respect to the agricultural income declared by him. Even before AO, no such details

Gurdeep Singh, Jammu and Kashmir vs. DCIT/ACIT Circle 1, Jammu, Jammu and Kashmir

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

ITA 294/ASR/2025[2010-11]Status: DisposedITAT Amritsar12 Mar 2026AY 2010-11

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

Section 143(3)Section 147Section 148Section 250Section 68

there was no new material which could warrant action u/s 147. (5) That the addition of Rs.450000/-made on account of unexplained cash credits u/s 68 confirmed by CIT(A) only on the basis that no PAN was submitted without appreciating that the said amount is part of regular books

Raja Mohle, Kawardha vs. Income Tax Officer-1(3), Bhilai, Durg

In the result, the appeal of the assessee is allowed as per aforesaid terms

ITA 821/RPR/2025[2017-18]Status: DisposedITAT Raipur12 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.821/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Raja Mohle Chote Ragra, Indauri, Kawardha-491 336 (C.G.) Pan: Bvrpm0901R .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(3), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 69A

here that Section 115BBE deals with tax on income referred to in Sections 68, 69, 69A, 69B, 69C, and 69D, which typically includes unexplained cash credits, investments expenditures, etc. and the Taxation Laws (Second Amendment) Act, 2016, passed after demonetization, increased the tax rate under Section 115BBE to 60% (plus

Vikas Chandrakantbhai Shah, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

ITA 25/AHD/2026[2019-20]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jignesh Parikh, ARFor Respondent: Shri C Dharani Nath, Sr. DR
Section 147Section 148Section 148ASection 151Section 68

Assessing Officer under section 69C was not appropriate and the same ought to have been made under section 68 of the Act as unexplained cash credit. Accordingly, while modifying the section under which the addition was made, the CIT(A) confirmed the addition of ₹99,80,000/- under section

Rajesh Pananalal Shah, Vadodara vs. Asstt. Unit, Juris. AO- Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 2581/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri C Dharani Nath, Sr. DRFor Respondent: Shri C Dharani Nath, Sr. DR
Section 115BSection 142(1)Section 143(2)Section 144Section 250Section 271ASection 68

documentary evidence and therefore made an addition of ₹1,00,04,345/- under section 68 of the Act treating the same as unexplained cash credits. The Assessing Officer further disallowed a sum of ₹6,45,356/- on account of business expenses which could not be verified, after comparing the expenses

Qmin Industries Limited, Ahmedabad vs. The ITO, Ward-7(2)(1), Ahmedabad

The appeal of the assessee is allowed for statistical purposes

ITA 1777/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Mahesh Chhajed, ARFor Respondent: Shri C Dharani Nath, Sr. DR
Section 115BSection 143(2)Section 68

appearing in the name of M/s Brand Cluster LLP remained unverified. Accordingly, the Assessing Officer treated the said amount as unexplained cash credit under section 68 read with section 115BBE of the Act and added the same to the income of the assessee. 5. Aggrieved by the assessment order

Narayanlal Bhanaji Prajapati, Ahmedabad vs. The ACIT, Central Circle-2(3), Ahmedabad

Accordingly, the appeal filed by the assessee is dismissed

ITA 588/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Hardik Vora, ARFor Respondent: Ms. Pallavi, CIT-DR & Shri Rameshwar P
Section 115BSection 132Section 153CSection 68

failed to satisfactorily explain the nature and source of the credit entries of ₹5,65,000/- and therefore treated the same as unexplained cash credits under section 68 of the Act and taxed the same under section 115BBE. 5. The Assessing Officer further noted that during the course

Kashi Nath Seth Sarraf Private Limited, Hardoi vs. DCIT, Sitapur

ITA 86/LKW/2024[2012-13]Status: DisposedITAT Lucknow12 Mar 2026AY 2012-13

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Respondent byFor Respondent: Shri Akshay Agrawal, Advocate
Section 142(1)Section 143(3)Section 147Section 148Section 151Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “B”, LUCKNOW BEFORE SHRI KUL BHARAT, VICE PRESIDENT AND SHRI ANADEE NATH

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1594/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

fact that the amount of Rs.14,43,53,102/- income from explained sources during the AY 2021-22 was to be considered as unexplained cash credit u/s 68 of the IT Act, 1961. 4. Whether on the facts and circumstances of the case ... Finally, the assessee’s submissions were rejected and alleged excess income as shown by the assessee was added as unexplained cash credit u/s 68 r.w.s. 115BBE of the Act. 2.7 The fifth addition was addition of difference in stock at jewellery showrooms. The assessee had two showrooms

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1593/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

fact that the amount of Rs.15,25,03,772/- income from explained sources during the AY 2020-21 was to be considered as unexplained cash credit u/s 68 of the IT Act, 1961. 1.4 The Ld. AR advanced arguments on legal grounds as well as on merits by drawing ... Finally, the assessee’s submissions were rejected and alleged excess income as shown by the assessee was added as unexplained cash credit u/s 68 r.w.s. 115BBE of the Act. 2.7 The last of the addition was addition of unexplained cash credit u/s 68 for Rs.207.40 Lacs. It transpired that