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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

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are

ITA 1123/PUN/2024[2014-15]Status: DisposedITAT Pune18 Dec 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024

Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

above reproduced paras, it emanates that the firm belief of the learned AO was, to tax the donations of Rs.1.39 CR as 'unexplained cash credit u/s 68 of the ITA, 1961. 11. Final assessment_u/s_115BBC-As against the firm belief till 29/11/2019, the learned AO, vide 147 order dated 24/12/2019 ... ambit of section 115BBC of the Act. Both provisions address unexplained or unverified receipts as section 68 of the Act dealing with unexplained cash credits and section 115BBC of the Act with anonymous donations received by charitable or religious institutions. Thus, the underlying facts and source of escapement remain

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are

ITA 1122/PUN/2024[2013-14]Status: DisposedITAT Pune18 Dec 2025AY 2013-14

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024

Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

Nos.1121 to 1126/PUN/2024 Rajarshi Shahu Shikshan Sanstha belief of the learned AO was, to tax the donations of Rs.1.39 CR as 'unexplained cash credit u/s 68 of the ITA, 1961. 11. Final assessment_u/s_115BBC-As against the firm belief till 29/11/2019, the learned AO, vide 147 order dated 24/12/2019, has taxed ... proceedings alleging that section 68 of the Act needs to be invoked and donations received during the year needs to be taxed as unexplained cash credit, however, the final outcome of the re-assessment proceedings is the addition u/s.115BBC of the Act. Whether section 68 and section 115BBC

Rajarshi Shahu Shikshan Sanstha Inam Dhamani, Sangli vs. ITO Exemption, Kolhapur

In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove

ITA 1121/PUN/2024[2012-13]Status: DisposedITAT Pune18 Dec 2025AY 2012-13

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde &
Section 115BSection 143(3)Section 147Section 148Section 155BSection 68

above reproduced paras, it emanates that the firm belief of the learned AO was, to tax the donations of Rs. 1.39 CR as 'unexplained cash credit u/s 68 of the ITA, 1961. 11. Final assessment u/s 115BBC-As against the firm belief till 29/11/2019, the learned AO, vide 147 order ... proceedings alleging that section 68 of the Act needs to be invoked and donations received during the year needs to be taxed as unexplained cash credit, however, the final outcome of the re-assessment proceedings is the addition u/s.115BBC of the Act. Whether section 68 and section 115BBC

Sushil Mitruka, Siliguri vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 2178/KOL/2025[2014-2015]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-2015

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

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

made by the ld. AO on account of cash deposits in the bank account by treating the same as unexplained cash credit u/s 68 of the Act. 4.1. The facts in brief qua this ground are that the assessee has a banking account with the Indian bank in Siliguri Branch ... submissions of the assessee and made an addition of ₹67,30,000/- was made u/s 68 of the Act on account of unexplained cash credit. 4.2. In the appellate proceedings the ld. CIT (A) partly allowed the appeal by sustaining the addition to the extent of ₹59,73,221/- while

DCIT, Central Circle-4(3), Kolkata vs. Arun Engineering Udyog Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1955/KOL/2025[2022-23]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-23

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit, Central Circle 4(3), Arun Engineering Udyog Kolkata Private Limited Aaykar Bhawan Poorva, 151, A, Cotton Street Vs. 110 Shantipally, Kolkata-700107 Burrabazaar West Bengal Kolkata-700007, West Bengal (Appellant) (Respondent) Pan No. Aalca8127A Assessee By : Shri Miraj D. Shah, Ar Revenue By : Shri Ruchika Sharma, Dr Date Of Hearing: 04.12.2025 Date Of Pronouncement: 18.12.2025 O R D E R

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Ruchika Sharma, DR
Section 133(6)Section 143(2)Section 143(3)Section 68

deleting the addition of ₹40 lacs as made by the ld. AO in respect of bogus unsecured loan as unexplained cash credit. 2.1. The facts in brief are that the assessee filed the return of income on 24.09.2022, declaring total income of ₹5,61,390/-. The return was selected ... loan were not established. Accordingly, the assessing officer made addition under section 68 of the Act. 3.1 While the assessing officer dealt with unexplained cash credit from the M/s. Satya Retail Private Limited and from M/s. J.A Infracon Private Limited in his order in paras 5.1 and 5.2 respectively

DCIT, Central Circle-4(3), Kolkata vs. Raja Shelters Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1760/KOL/2025[2022-23]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-23

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 132Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

questionnaire and assessment order u/s 143(3) of the Act was passed on 22.03.2024 making an addition of Rs.6,28,00,000/- as unexplained cash credit u/s 68 of the Act on account of unsecured loan. 3. Aggrieved by the said order, the assessee preferred appeal before ... Assessee Company, under section 143(3) of the Act wherein the loan credits received from six loan creditors were added as unexplained cash credit under Section 68 of the Income Tax Act, 1961. The said Assessment Order was challenged before the Hon'ble Calcutta High Court in Writ Jurisdiction

DCIT, Central Circle-4(3), Kolkata vs. Ashok Kumar Kayan, Kolkata

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

ITA 1757/KOL/2025[2010-11]Status: DisposedITAT Kolkata18 Dec 2025AY 2010-11

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2010-11 Dcit, Central Circle-4(3), Kolkata……...…………….……….……….……Appellant Vs. Ashok Kumar Kayan……………………………………….....……...…..…..Respondent 1, R N Mukherjee Road, Dalhousie, Kol-1.. [Pan: Alkpk2298K] Appearances By: Pradeep Dung Dung, Sr. Dr, Appeared On Behalf Of The Appellant. Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 23.07.2024 Of The Cit(A)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Appeal Has Been Filed By The Revenue With A Delay Of 04 Days. The Revenue Has Filed A Petition For Condonation Of The Delay. After Considering The Reasons Cited In The Petition For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 139(1)Section 147Section 148Section 250Section 68

assessment order u/s 147 r.w.s 144 of the Act determining a total Income of Rs.2,24,94,270/- by making an addition of Unexplained cash credit u/s 68 of the Act of Rs.2,17,00,000/-. 4. Aggrieved by the said order, the assessee preferred appeal before

M/S. Akshara Abasan Private Limited, Kolkata vs. ITO, Ward 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1638/KOL/2025[2012-2013]Status: DisposedITAT Kolkata18 Dec 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 131Section 133(6)Section 139(1)Section 143(3)Section 14ASection 250Section 68

order of Ld. CIT(A) confirming the addition of Rs.1,47,20,000/- as made by the Assessing Officer in respect of unexplained cash credit u/s 68 of the Act. 2. Facts in brief are that the assessee engaged in the business of real estate and the assessee filed return ... treating the share capital money received along with the premium amounting to Rs.1,47,20,000/- as unexplained cash credit u/s 68 of the Act by adding the same to the income besides making disallowance u/s 14A Rs.3,36,784/-. 4. In the appellate proceedings, the Ld. CIT(A) confirmed

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1631/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

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

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

made by the ld. AO on account of cash deposits in the bank account by treating the same as unexplained cash credit u/s 68 of the Act. 4.1. The facts in brief qua this ground are that the assessee has a banking account with the Indian bank in Siliguri Branch ... submissions of the assessee and made an addition of ₹67,30,000/- was made u/s 68 of the Act on account of unexplained cash credit. 4.2. In the appellate proceedings the ld. CIT (A) partly allowed the appeal by sustaining the addition to the extent of ₹59,73,221/- while

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals

ITA 1630/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

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

Section 139(1)Section 144BSection 147Section 148Section 148(2)

made by the Ld. AO on account of cash deposits in the bank account by treating the same as unexplained cash credit u/s 68 of the Act. 4. 1. The facts in brief qua this ground are that the assessee has a banking account with the Indian bank in Siliguri ... submissions of the assessee and made an addition of ₹67,30,000/- was made u/s 68 of the Act on account of unexplained cash credit. 4. 2. In the appellate proceedings the Ld. CIT (A) partly allowed the appeal by sustaining the addition to the extent

DCIT, Circle-1, Siliguri vs. Sushil Mitruka, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1613/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

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

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

made by the ld. AO on account of cash deposits in the bank account by treating the same as unexplained cash credit u/s 68 of the Act. 4.1. The facts in brief qua this ground are that the assessee has a banking account with the Indian bank in Siliguri Branch ... submissions of the assessee and made an addition of ₹67,30,000/- was made u/s 68 of the Act on account of unexplained cash credit. 4.2. In the appellate proceedings the ld. CIT (A) partly allowed the appeal by sustaining the addition to the extent of ₹59,73,221/- while

Bongaon Co-Operative Credit Society Limited, Bongaon vs. DCIT, Circle 32, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1371/KOL/2025[2022-2023]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-2023

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2022-23 Bongaon Cooperative Credit Society Ltd..…………….……….……….……Appellant First Floor, Banerjee Market Jessore Road, Bongaon, Dist: North 24 Parganas, W.B - 743235.. [Pan: Aaaab6325N] Vs. Dcit, Circle-32, Kolkata….…………...…………………….....……...…..…..Respondent Appearances By: S. Ghosh, Ca, Appeared On Behalf Of The Appellant. Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Year Under Consideration On 28.08.2022 Declaring Nil Income After Claiming Deduction U/S 80P Of The Act Of Rs.25,75,431.98/- . The Case Of The Assessee Was Selected For Scrutiny Through Cass. The Assessment Was Completed Vide Order U/S 143(3) R.W.S. 144B Of The Act Dated 15.03.2024 Determining Total Income At Rs.71,81,740/- By Disallowing Deduction U/S 80P Of The Act With Regard To The Interest Income Received From Banks. Bongaon Cooperative Credit Society Ltd 3. Aggrieved By The Said Order, The Assessee Preferred Appeal Before The Ld. Cit(A) Wherein The Appeal Of The Assessee Has Been Dismissed.

Section 143(3)Section 250Section 68Section 80PSection 80P(2)(d)

carefully considered the rival submissions and also gone through the authorities relied on by either side. Regarding the addition made on account of unexplained cash credit the reliance placed on the case of Sri Bhageeratha Pattina Sahakara Sangha Niyamitha (supra) is acceptable considering that the facts are remarkably similar

DCIT, Central Circle-1(4), Kolkata vs. Educo Ventures Pvt Ltd., Kolkata

Appeal is dismissed

ITA 2144/KOL/2024[2015-16]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-16

Bench: the AO.

Section 133ASection 147Section 250Section 68

from M/s Qaulity Vinimay Pvt. Ltd. by way of advance. The AO added the same u/s 68 of the Act as unexplained cash credit on the ground that the assessee could not prove the creditworthiness of M/s Quality Vinimay Pvt. Ltd. and the genuineness of the transaction. Therefore, treated ... parties one M/s Bholenath Commonsale Pvt. Ltd., Anamika Dealmark Pvt. Ltd. and Eysore Tradecom Pvt. Ltd. However, the AO treated the same as unexplained cash credit on the ground that the assessee has failed to prove the creditworthiness of the creditors and genuineness of the transactions. Educo Ventures

DCIT Central Circle 1(4), Kolkata vs. Educo Ventures Pvt Ltd, Kolkata

Appeal is dismissed

ITA 2125/KOL/2024[2014-15]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-15

Bench: the AO.

Section 133ASection 147Section 250Section 68

from M/s Qaulity Vinimay Pvt. Ltd. by way of advance. The AO added the same u/s 68 of the Act as unexplained cash credit on the ground that the assessee could not prove the creditworthiness of M/s Quality Vinimay Pvt. Ltd. and the genuineness of the transaction. Therefore, treated ... parties one M/s Bholenath Commonsale Pvt. Ltd., Anamika Dealmark Pvt. Ltd. and Eysore Tradecom Pvt. Ltd. However, the AO treated the same as unexplained cash credit on the ground that the assessee has failed to prove the creditworthiness of the creditors and genuineness of the transactions. Educo Ventures

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

ITA 2025/KOL/2024[2020-2021]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-2021

Bench: the AO.

Section 133ASection 147Section 250Section 68

from M/s Qaulity Vinimay Pvt. Ltd. by way of advance. The AO added the same u/s 68 of the Act as unexplained cash credit on the ground that the assessee could not prove the creditworthiness of M/s Quality Vinimay Pvt. Ltd. and the genuineness of the transaction. Therefore, treated ... parties one M/s Bholenath Commonsale Pvt. Ltd., Anamika Dealmark Pvt. Ltd. and Eysore Tradecom Pvt. Ltd. However, the AO treated the same as unexplained cash credit on the ground that the assessee has failed to prove the creditworthiness of the creditors and genuineness of the transactions. Educo Ventures

Educo Ventures Pvt. Ltd., Kolkata vs. D.C.I.T., Central Circle - 1(4), Kolkata

Appeal is dismissed

ITA 2024/KOL/2024[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Bench: the AO.

Section 133ASection 147Section 250Section 68

from M/s Qaulity Vinimay Pvt. Ltd. by way of advance. The AO added the same u/s 68 of the Act as unexplained cash credit on the ground that the assessee could not prove the creditworthiness of M/s Quality Vinimay Pvt. Ltd. and the genuineness of the transaction. Therefore, treated ... parties one M/s Bholenath Commonsale Pvt. Ltd., Anamika Dealmark Pvt. Ltd. and Eysore Tradecom Pvt. Ltd. However, the AO treated the same as unexplained cash credit on the ground that the assessee has failed to prove the creditworthiness of the creditors and genuineness of the transactions. Educo Ventures

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Subramaniam Kathiresan, Chennai

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

ITA 899/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Dec 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. N. Arjun Raj, Advocate &For Respondent: Ms. Gauthami Manivasagam
Section 132Section 153Section 153ASection 153A(1)Section 153C

impugned re-assessment order, we note that the only addition made by the AO in AY 2011-12 was on account of unexplained cash credit represented by share application monies of Rs. 5,38,35,000/- u/s 68 of the Act. According to the AO, the source of source ... monies received from shareholder, M/s Hari Trafin Pvt Ltd was not properly explained, and therefore the same was added as unexplained cash credit u/s 68 of the Act. As noted above, the additions on account of unexplained cash credit and that too share capital, which is in the nature

Priyanka Lalitkumar Raizada, Mumbai vs. DCIT Circle 42(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4379/MUM/2025[2014-15]Status: DisposedITAT Mumbai18 Dec 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawalpriyanka Lalitkumar Raizada Vs Dcit Circle 42(3)(1), C/O Ca Himanshu Gandhi, 16Th Mumbai Floor, D Wing, Trade World Kautilya Bhavan, Bandra Building, Kamala Mills Compound, Kurla Complex, Bandra Lower Parel, Mumbai 400013 East, Mumbai 400051 Pan: (Aekpr3350J) Appellant Respondent Present For: Appellant By : Shri Himanshu Gandhi, Ca Respondent By : Shri Virabhadra Mahajan, Sr. Dr (Virtually Present) Date Of Hearing : 22.09.2025 Date Of Pronouncement : 18.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2023-24/1058479077(1) Dated 05.12.2023 Passed Against Assessment Order U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 26.12.2016 For Ay 2014-15. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. On The Facts & Circumstances Of The Case & Law, The Ld. Cti (A) Erred In Confirming Addition Of Rs. 21,50,540/-Being Sale Proceeds Of Inherited Jewellery As Unexplained Cash Credits U/S 68 Of The Income Tax Act, 1961. 2

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 143(3)Section 234BSection 271(1)(c)Section 68

case and law, the Ld. CTI (A) erred in confirming addition of Rs. 21,50,540/-being sale proceeds of inherited jewellery as unexplained cash credits u/s 68 of the Income Tax Act, 1961. 2 ITA No.4379/MUM/2025 AY: 2014-15 Priyanka Lalitkumar Raizada 2. On the facts and circumstances ... gold ornaments. 5. Ld. AO after considering all the submissions concluded to treat the amount of sale consideration of Rs.21,50,540/- as unexplained cash credit u/s. 68 by observing that assessee could not produce documentary evidences in support of purchase of gold jewellery by his father as well

Alpesh K. Ajmera HUF, Mumbai vs. Income Tax Officer Ward 18(1)(1), Mumbai

In the result, the appeal filed by the assessee stands

ITA 4041/MUM/2025[2011-12]Status: DisposedITAT Mumbai18 Dec 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 147Section 68Section 69

accommodation entry', accordingly made additions u/s 68 and 69C of the Act in the total income of the assessee on account of unexplained cash credit and unexplained expenditure respectively and the said additions were also upheld by Ld. CIT(A) thereby disposing the appeal filed by the assessee. 4. After ... abnormal price rise which is not backed by financial fundamentals and the entire transactions represented prearranged accommodation entry, treating the sale proceeds as ‘unexplained cash credit' u/s 68 of the Act. Whereas Ld. AR specifically submitted that investigation Wing", "Findings in the case of Assessee", "Share Purchase/Sale Analysis

Assistant Commissioner of Income Tax, Central Circle, Jamshedpur vs. Benko Traders Private Limited, Kolkata

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

ITA 436/RAN/2024[2015]Status: DisposedITAT Ranchi17 Dec 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

Section 139Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69C

complied with. According to the AO, income of ₹1,64,60,100 representing sale proceeds of shares was to be treated as unexplained cash credit under section 68 of the Act, along with commission expenditure of ₹3,29,202 @2% under section 69C, and unsecured loans ... justified to made the addition of Rs.59,00,000/- on account of loan from shell entities treated as unexplained cash credit u/s.68 of the IT Act as it was based on surmises and conjecture. On perusal of material available on record, it is noticed that during the year under consideration