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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

Shri Bhupendra Kumar Agarwal, Lucknow vs. Asstt. Commissioner of Income Tax, Range-III, Lucknow

In the result, the appeal of the assessee is partly allowed

ITA 122/LKW/2021[2014-2015]Status: DisposedITAT Lucknow17 Oct 2025AY 2014-2015

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2014-15 Dcit, Range-3 V. Shri Bhupendra Kumar 27/2, Raja Ram Mohan Rai Agarwal Marg, P.K. Complex, Lucknow- Bhagwati Industrial 226001. Compound, Mohibullapur, Lucknow-226020. Tan/Pan:Adppa9782P (Appellant) (Respondent) Assessment Year: 2014-15 Shri Bhupendra Kumar V. Acit Range-Iii Agarwal Lucknow-226010. Bhagwati Industrial Compound, Mohibullapur, Lucknow- 226020. Tan/Pan: Adppa9782P (Appellant) (Respondent) Appellant By: Shri Suyash Agarwal, Adv Respondent By: Shri R. K. Agarwal, Cit(Dr) Date Of Hearing: 02 09 2025 Date Of Pronouncement: 17 10 2025 O R D E R

For Appellant: Shri Suyash Agarwal, AdvFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 133(6)Section 142(1)Section 143(2)Section 68

balances sin respect of these two Sundry Creditors are Rs.87,280/- and Rs. 93,800/-. Thus, Rs 1,81,080/- is held as unexplained cash credit u/s 68. Besides the above, the differences of Rs.1,65,963/- in case of above two Creditors – Amkap Marketing Pvt. Ltd. (Shree KashiVishwanath ... credit balances in respect of these two Sundry Creditors are Rs.87,280 and Rs. 93,800. Thus, Rs.1,81,080/- is held as unexplained cash credit u/s 68. Besides the above, the differences of Rs.1,65,963/- in case of above two Creditors - Amkap Marketing Pvt. Ltd. (Shree KashiVishwanath

DCIT, Range-3, Lucknow vs. Shri Bhupendra Kumar Agarwal, Lucknow

In the result, the appeal of the assessee is partly allowed

ITA 410/LKW/2020[2014-15]Status: DisposedITAT Lucknow17 Oct 2025AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2014-15 Dcit, Range-3 V. Shri Bhupendra Kumar 27/2, Raja Ram Mohan Rai Agarwal Marg, P.K. Complex, Lucknow- Bhagwati Industrial 226001. Compound, Mohibullapur, Lucknow-226020. Tan/Pan:Adppa9782P (Appellant) (Respondent) Assessment Year: 2014-15 Shri Bhupendra Kumar V. Acit Range-Iii Agarwal Lucknow-226010. Bhagwati Industrial Compound, Mohibullapur, Lucknow- 226020. Tan/Pan: Adppa9782P (Appellant) (Respondent) Appellant By: Shri Suyash Agarwal, Adv Respondent By: Shri R. K. Agarwal, Cit(Dr) Date Of Hearing: 02 09 2025 Date Of Pronouncement: 17 10 2025 O R D E R

For Appellant: Shri Suyash Agarwal, AdvFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 133(6)Section 142(1)Section 143(2)Section 68

balances sin respect of these two Sundry Creditors are Rs.87,280/- and Rs. 93,800/-. Thus, Rs 1,81,080/- is held as unexplained cash credit u/s 68. Besides the above, the differences of Rs.1,65,963/- in case of above two Creditors – Amkap Marketing Pvt. Ltd. (Shree KashiVishwanath ... credit balances in respect of these two Sundry Creditors are Rs.87,280 and Rs. 93,800. Thus, Rs.1,81,080/- is held as unexplained cash credit u/s 68. Besides the above, the differences of Rs.1,65,963/- in case of above two Creditors - Amkap Marketing Pvt. Ltd. (Shree KashiVishwanath

Bimla Devi Gupta, Kolkata vs. ITO, Ward-37(1), Kolkata

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 487/KOL/2024[2013-14]Status: DisposedITAT Kolkata17 Oct 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Bimla Devi Gupta…..………….……………………….……….……….……Appellant P-77, Cit Road, Kakurgachi, Kol- 700054.. [Pan: Agfpg3331D] Vs. Ito, Ward-37(1), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Anil Kochar, Advocate, Appeared On Behalf Of The Appellant. Shri Pradip Kr. Biswas, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.01.2024 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 139Section 147Section 250Section 68

been made by the Assessing Officer u/s 147 r.w.s. 144B of the Act making an addition of Rs.4,22,00,000/- as unexplained cash credit u/s 68 of the Act. 3. Aggrieved by the said order, the assessee preferred appeal before the ld. CIT(A) wherein the appeal ... nature and source about the credits and credit amount of Rs.2,63,14,000/- appearing in the bank account has been treated as unexplained cash credit u/s 68 of the Act. The ld. AR on this ground has prayed for reverification. 5. The ld. DR did not raise any objection

Abdul Razaque, Jabalpur vs. ACIT Circle 2(1), Jabalpur

In the result, ground no. 1 is allowed while ground nos

ITA 84/JAB/2024[2016-17]Status: DisposedITAT Jabalpur16 Oct 2025AY 2016-17

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Abdul Razaque, Vs. Acit, 903, Badi Omti, Jabalpur, M.P. Circle-2(1), Jabalpur Pan:Afgpr9967N (Appellant) (Respondent) Assessee By: Sh. Sapan Usrethe, Advocate Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 16.10.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl Jcit(A), Mysore, Wherein The Ld. Addl Jcit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Ao Dated 19.11.2018, Passed Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. The Learned Commissioner Of Income Tax (Appeal) Addl/Jaddl Jcit(A)- Mysore Was Not Justified In Deciding The Legal Ground That Case Was Selected For Limited Scrutiny Under Cass To Examine The Reasons Of (I) Return Filed After 7.11.2016' & Cash Deposit During Demonetization Period & Addition Was Made On Some Other Issue Which Was Not The Reason For Selection & Without Taking Any Approval From Higher Authorities. 2. The Learned Commissioner Of Income Tax (Appeal) Addl/Jaddl Jcit(A)-Mysore Was Not Justified In Confirming The Addition Of Rs. 4,48,584 By Ignoring All The Evidences & Documents By Simply Observing That No New Documents Were Filed Even Though Documents Which Are Filed Are Sufficient & Self-Explanatory & The Order Of Learned Cit Appeals Is Passed In A Mechanical Manner, Without Any Application Of Mind & Appears That It Was Passed With Predetermined Mind.

For Appellant: Sh. Sapan Usrethe, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 143(3)Section 68

withdrawal. However, the ld. AO did not accept the said submission and he added back the sum of Rs. 4,48,584/- as unexplained cash credit under section 68 of the Act. He also made an addition of Rs. 10,200/- on account of unexplained expenditure in the purchase

Deputy Commissioner of Income Tax, Central Circel-4, Surat vs. Bhartiben Bholabhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 980/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

/SRT/2024 A.Y 21 -22 Radadiya Group Act and (ii) addition of Rs.11,72,000/- on account of unexplained cash credits u/s 68 of the Act. 13. Regarding the addition made of Rs.2,00,81,625/- on account of unexplained money u/s 69A of the Act, it was observed