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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

Shiv Shanker, Yamuna Nagar Haryana vs. Income Tax Officer, Ward 5 Yamunanagar, Yamunanagar Haryana

The appeal stand allowed for statistical purposes

ITA 870/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh08 Dec 2025AY 2016-17

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.870/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2016-17) Shri Shiv Shanker Ito Ward-5, Yamuna Nagar Prop. M/S Shyam Footwear Aaykar Bhawan, बनाम/ Vs. 14 Gandhi Market, Yamuna Nagar Sector-17, Yamuna Nagar, Haryana - 135001 Haryana- 135003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acqps-7150-P (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. B.M. Monga (Advocate) & Sh. Rohit Kaura (Advocate) – Ld. Ars ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) - Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 08-12-2025 घोषणाकीतारीख /Date Of Pronouncement 09-12-2025 :

For Appellant: Sh. B.M. Monga (Advocate) and Sh. Rohit KauraFor Respondent: Dr. Ranjit Kaur (Addl. CIT) - Sr. DR
Section 143(3)Section 144Section 251(1)(a)Section 68

order, Ld. AO disbelieved the sales of the assessee as made to Shri Sunil Kumar prop. Aggarwal Enterprises and added the same as unexplained cash credit u/s 68. The assessment was framed u/s 143(3) r.w.s. 147 of the Act. The Ld. CIT(A), assuming the assessment

Vinayak Hanumantrao Ghorpade, Pune vs. Income Tax Officer, Pune

In the result, appeal in ITA No

ITA 1439/PUN/2024[AY2020-21]Status: DisposedITAT Pune08 Dec 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

Section 153ASection 250Section 43BSection 68Section 80C

circumstances of the case and in law Ld. CIT has erred in making an addition of Rs.64,81,702/- under section 68- unexplained cash credits, being unsecured loans by concluding that 2 ITA Nos.1438 & 1439/PUN/2024 [A] appellant has failed to discharge its primary onus, given an opportunity your appellant ... circumstances of the case and in law Ld. CIT has erred in making an addition of Rs. 3,75,000/- under section 68- unexplained cash credits, being unsecured loans by concluding that appellant has failed to discharge its primary onus, given an opportunity your appellant is in position to provide

Vinayak Hanumantrao Ghorpade, Pune vs. Vaishnavi Satish Bankar, Pune

In the result, appeal in ITA No

ITA 1438/PUN/2024[AY2019-20]Status: DisposedITAT Pune08 Dec 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.1438 & 1439/Pun/2024 निर्धारण वषा / Assessment Years: 2019-20 & 2020-21 Vinayak Hanumantrao V Vaishnavi Satish Bankar, Ghorpade, S. Pune. F.No.7, Plot No.60/61, S.No.165/1B, Shivanjali, Near Central Circle-1(3), Pune. Mahadev Temple, Indira Nagar, Pune – 411033. Pan: Afdpg6919A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Shri Aviyogi Ambadkar –Addl.Cit Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Common Order Of Ld.Commissioner Of Income Tax(Appeal), Pune-11 Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2019-20 & 2020-21, Both Dated 02.05.2024 Emanating From Separate Assessment Order U/S.153A R.W.S 144 Of The I.T.Act, Both Dated 23.09.2021.For The Sake Of Convenience, These Two Appeals

Section 153ASection 250Section 43BSection 68Section 80C

circumstances of the case and in law Ld. CIT has erred in making an addition of Rs.64,81,702/- under section 68- unexplained cash credits, being unsecured loans by concluding that 2 ITA Nos.1438 & 1439/PUN/2024 [A] appellant has failed to discharge its primary onus, given an opportunity your appellant ... circumstances of the case and in law Ld. CIT has erred in making an addition of Rs. 3,75,000/- under section 68- unexplained cash credits, being unsecured loans by concluding that appellant has failed to discharge its primary onus, given an opportunity your appellant is in position to provide