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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

Riddhi Siddhi Mahila Nagari Co-Op Credit Society Ltd, Karad vs. CIT (Appeals), Delhi

ITA 2216/PUN/2025[2019-20]Status: DisposedITAT Pune19 Nov 2025AY 2019-20

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2216/Pun/2025 िनधा"रण वष" / Assessment Year : 2019-20 Riddhi Siddhi Mahila Nagari Vs. Assessment Unit, Co-Op. Credit Society Ltd., Income Tax Department. Palkar House, 157, Guruwar Peth, Shri Vitthal Chouk, Karad- 415110. Pan : Aacar0958D Appellant Respondent Assessee By : Shri Vijaykumar N. Kashirsagar Revenue By : Shri Vinod Pawar (Virtual) Date Of Hearing : 28.10.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2019-20. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Primary Credit Co-Operative Society Engaged In The Business Of Providing Credit Facilities To Its Members & Also In Accepting Deposits From Them. On The Basis Of Information That The Assessee Has Made One Time Deposit Of Rs.5,95,522/- & Tds Of More Than Rs.7,72,686/-

For Appellant: Shri Vijaykumar N. KashirsagarFor Respondent: Shri Vinod Pawar (Virtual)
Section 139(1)Section 142(1)Section 147Section 148Section 194ASection 80ASection 80P(2)(c)Section 80P(2)(d)

receipts/ deposit from the members and therefore treated the whole of the deposit of Rs.7,81,16,000/- in the bank account as unexplained cash credit and also treated the interest income received from PALKAR’s as undisclosed interest income and also disallowed the deduction claimed under section

Deepali Kapoor, Hyderabad vs. ITO., Ward-12(1), Hyderabad

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

ITA 1097/HYD/2025[2022-2023]Status: DisposedITAT Hyderabad19 Nov 2025AY 2022-2023

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1097/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Ms. Deepali Kapoor Vs. Income Tax Officer Hyderabad Ward 12 (1) Pan:Annpk2904M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Ms. Deepali Kapoor (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 10.06.2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Impugned Order Of The Learned Authorities Below In So Far As It Is Against The Appellant Is Opposed To Law, Weight Of Page 1 Of 7

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: : Shri R. Kumaran, Sr. DR
Section 143(2)Section 143(3)Section 144BSection 234BSection 68

cannot be invoked. In the present case, household expenses given by a spouse for daily living requirements cannot be treated as unexplained cash credit within the four corner of section 68 of the Act. Hence, on the basis of the facts of the present case, we hold that section