← 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

Suryanarayana Gandla, Anantapur vs. ACIT., Circle - 1, Anantapur

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

ITA 1122/HYD/2025[2017-18]Status: DisposedITAT Hyderabad31 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1122/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Shri Suryanarayana Gandla, Asst. Commissioner Of Income Vs. Tax, Circle-1, Anantapur. Anantapur. Pan: Abipg4005A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasaad, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Pronouncement: 31/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M. :

For Appellant: Shri K.A. Sai Prasaad, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 143(2)Section 143(3)Section 40A(3)Section 68

explain the source of such deposits. However, the Ld. AO, not being convinced with the explanation offered, treated the entire amount as unexplained cash credits under section 68 of the Act and added the same to the income of the assessee. The Ld. AO further made a disallowance of Rs.3 ... deposited cash of Rs.96,26,300/- in his bank accounts during the demonetisation period. The Ld. AO treated the said deposits as unexplained cash credits under section 68 of the Act. The Ld. AR submitted that out of the total cash deposits of Rs.96,26,300/- made during the demonetisation

Shri V. Natarajan (Individual), Rasipuram vs. ACIT, Central Circle, Salem

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

ITA 1801/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Oct 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

failed to offer any explanation for source cash deposits in bank account, the AO has treated the amount Rs..38,79,163/- as unexplained cash credit u/s 68 and applied tax rate u/s 155BBE of IT Act. 7.4.3 During appeal proceedings, though appellant has raised the Ground against treating ... amount as unexplained cash credit, no specific submissions are made except stating that the same amount was offered as income both in original return filed for the year as well as in return filed u/s 153A. He filed copy of computation statement filed along with original return as a proof

Varadappan Natarajan, Rasipuram vs. ACIT, Central Circle, Salem

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

ITA 1535/CHNY/2024[2016-17]Status: DisposedITAT Chennai31 Oct 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

failed to offer any explanation for source cash deposits in bank account, the AO has treated the amount Rs..38,79,163/- as unexplained cash credit u/s 68 and applied tax rate u/s 155BBE of IT Act. 7.4.3 During appeal proceedings, though appellant has raised the Ground against treating ... amount as unexplained cash credit, no specific submissions are made except stating that the same amount was offered as income both in original return filed for the year as well as in return filed u/s 153A. He filed copy of computation statement filed along with original return as a proof

Prakash Mahadev Gaikwad, Belapur vs. Commissioner of Income-Tax (Appeals), Delhi

In the result assessee appeal is allowed for statistical purposes

ITA 5209/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year: 2014-15 Prakash Mahadev Gaikwad Commissioner Of 53, Royal Castle, Plot No. 75, Income-Tax (Appeals) Sector- 19/20 Palm Beach Commissioner Of Income Vs. Road, Belapur, Navi Mumbai Tax Appeal Mumbai 46, Pan: Adqpg0694P Ward 42(3)(1), Kautilya Bhavan, Mumbai, Ito 42(3)(1), Mumbai (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Praveen K. Srivastav, Ld. Sr.D.R. Date Of Hearing : 09.10.2025 Date Of Pronouncement : 31.10.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Cit(A)) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2014-15. 2. Admittedly In The Instant Case, The Ld. Commissioner In The Appeal Filed By The Assessee Against The Assessment Order Dated 27.12.2016 U/S 143(3) Of The Act, Whereby 3 Additions Of Rs. 51,14,040, Rs. 81,94,000/- & 1,44,998/- Were Respectively Made On Account Of Unexplained Investment U/S 69 Of The Act, Unexplained Cash Credit U/S 68 Of The Act & Disallowance On 2 Prakash Mahadev Gaikwad Account Of Interest Income Without Seeking Exemption U/S 80Tt Of The Act, Issued Various Notices To The Assessee, However, The Assessee Failed To Comply With The Same & Therefore In The Constrained Circumstance, The Ld. Commissioner Affirmed The Aforesaid Addition By Dismissing The Appeal Of The Assessee.

For Appellant: NoneFor Respondent: Shri Praveen K. Srivastav, Ld. Sr.D.R
Section 143(3)Section 250Section 68Section 69Section 80T

were respectively made on account of unexplained investment u/s 69 of the Act, unexplained cash credit u/s 68 of the Act and disallowance on 2 Prakash Mahadev Gaikwad account of interest income without seeking exemption u/s 80TT of the Act, issued various notices to the Assessee, however, the Assessee failed