← 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

Ranjith Kumar, Chennai vs. ITO, Ncw-19(6), Chennai

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

ITA 2041/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Oct 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2041/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Ranjith Kumar, Vs. The Income Tax Officer, 418A, Flat No. 1 & 2, 1St Floor, 2Nd Link Non-Corporate Ward 19(6), Road, Sadasivam Nagar North, Chennai. Madipakkam, Chennai 600 091. [Pan: Adnpr0643L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri C.P. Solomon, Jcit सुनवाई की तारीख/ Date Of Hearing : 23.10.2025 घोषणा की तारीख /Date Of Pronouncement : 28.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.05.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 358 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri C.P. Solomon, JCIT
Section 148Section 69A

statutory notices and estimated Rs. 16,81,564/- at 3% of total credits in the current account treating the same as unexplained cash credit on account of unexplained/unaccounted income under section 69A of the Act, which is clear from para 5 of the impugned order. It is noted that

Deepsikha Distributors Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(1), Kolkata

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

ITA 1714/KOL/2025[2012-2013]Status: DisposedITAT Kolkata27 Oct 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Deepsikha Distributors Pvt. Ltd..……………………………….…….……Appellant 15/2/1, Deodar Street, Kolkata-700019. [Pan: Aaacd9515E] Vs. Ito, Ward-6(1), Kolkata..………………………..………...……...…..…..Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 12.06.25 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”). Brief Facts Of The Case Are That The Assessee Is Engaged In The 2. Business Of Investment In Shares & Filed Its Return Of Income On For A.Y. 2012-13 U/S 139(1) Of The Act Declaring Total Income Of Rs.279/-. The Return Was Selected For Scrutiny & An Order U/S 143(3) Of The Act Was Passed On 17.03.2015 Assessing Total Income Of The Assessee At Rs.1,15,00,279/- By Adding Rs.1,15,00,000/- As Unexplained Cash Credit U/S 68 Of The Act. After That, The Assessee Went In Appeal Before The Ld. Cit(A) & The Ld. Cit(A) Vide Order Dated 30.06.2015 Allowed The Appeal Deepsikha Distributors Pvt. Ltd Of The Assessee. Thereafter, The Revenue Preferred Appeal Before The Itat Wherein The Tribunal Set Aside The Order Of The Ld. Cit(A) & Asked The Assessing Officer To Pass De Novo Assessment & The Assessing Officer Vide Fresh Assessment Order U/S 254/250/143(3) Of The Act Sustained The Same Addition Of Rs.1,15,00,000/- U/S 68 Of The Act As Unexplained Cash Credit.

Section 139(1)Section 143(3)Section 250Section 254Section 68

passed on 17.03.2015 assessing total income of the assessee at Rs.1,15,00,279/- by adding Rs.1,15,00,000/- as unexplained cash credit u/s 68 of the Act. After that, the assessee went in appeal before the ld. CIT(A) and the ld. CIT(A) vide order dated ... assessment order u/s 254/250/143(3) of the Act sustained the same addition of Rs.1,15,00,000/- u/s 68 of the Act as unexplained cash credit. 3. Aggrieved by the said order, the assessee preferred an appeal before the ld. CIT(A) wherein the appeal has been dismissed by observing