“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

Ram Baburao Salve, Mumbai vs. ITO WD 17(3)(!), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 5370/MUM/2018[2011-12]Status: DisposedITAT Mumbai13 Oct 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agarwal & Assessment Year: 2011-12

Section 143(3)Section 263Section 68

absence of any explanation from you for the sources of cash deposit, the same will be treated as unexplained cash credit u/s.68 of the Income-tax Act and will be added back to your total income." 13. We also noticed that during the course of hearing of the original assessment

Photon Ultrawave Private Limited, Delhi vs. DCIT, Circle-19(2), Delhi

Appeal is allowed in above terms

ITA 2638/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18

Section 142(1)Section 143(3)Section 14ASection 68

terms. 2 | P a g e 4. The assessee’s latter substantive ground raised in the instant appeal seeks to reverse section 68 unexplained cash credits addition of Rs.28,00,00,000/- received from its holding group M/s. P.R. Infrastructure Pvt. Ltd. as share capital. The Revenue vehemently contends that ... explained source of the impugned investments of Rs.28 crores in it’s scrutiny assessment, the same could not be treated as unexplained cash credits in the appellant’s case as is the Revenue’s stand before us. We accordingly conclude that the impugned section 68 additions of Rs.28 crores

Arun Pruthi, Rajouri Garden New Delhi vs. Commissioner of Income-Tax (Appeals), ITO

Accordingly, the addition made by the AO of Rs 8,40,000/- is restricted to Rs 6,12,000/- and the grounds raised in this respect stands partly allowed

ITA 6002/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18

Section 143(3)Section 23(1)(a)Section 23(2)

very terms therefore. Ordered accordingly. 4. Next comes the latter issue between the parties wherein the learned CIT(A)/ NFAC has confirmed the unexplained cash credits addition of unexplained cash deposits of Rs. 11.75 lakhs during demonetization to the extent of 50% in the lower appellate discussion. Learned DR could

Rupali Gupta, Meerut vs. National Faceless Appeal Centre (NFAC), National Faceless Appeal Centre Delhi

Appeal is dismissed

ITA 5182/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Oct 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2014-15 Vs. National Rupali Gupta, Faceless Appeal 273, Budhana Gate, Meerut, Centre, Delhi Uttar Pradesh Pan: Ajcpg6194L (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 13.10.2025 Date Of Pronouncement 13.10.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2014-15, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1068639287(1), Dated 12.09.2024 Involving Proceedings Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Case Called Twice. None Appears At The Assessee’S Behest. She Had Also Not Put In Appearance On All The Earlier Five Opportunities Of Hearing As Well. The Assessee Is Accordingly Proceeded Ex-Parte. 2. It Next Transpires With The Able Assistance Coming From The Revenue Side That Both The Learned Lower Authorities Have Inter Alia Treated The Assessee’S Alleged Capital Gains Derived From Sale Of Shares Amounting To Rs.48,28,090/- As Bogus Followed By 5% Commission Expenditure Thereupon Coming To Rs.2,41,405/- As Unexplained Under Section 69C; Respectively, In Assessment Order Dated 28Th March, 2022 & Upheld In The Lower Appellate Discussion, As Followed: “4. The Present Appeal Was Filed By The Appellant On 21.04.2022 By Raising 20 Grounds Of Appeal. During The Course Of Appeal Proceedings, Hearing Notices Were Sent On 15.07.2024, 01.08.2024 & 20.08.2024. In Response To The Notices Issued The Appellant Filed Only A Brief Written Submission As Under:

Section 147Section 68Section 69C

LTCG. The AO dealt the issue exhaustively and concluded that the amount received in the form of sale of shares was nothing but unexplained cash credit u/s 68 of the IT Act. In these kind of transactions, certain brokers or commission agents used to charge certain percentage of money

DCIT, Circle - 19(1), New Delhi vs. Prime Comfort Products Pvt. Ltd., Delhi

Appeal is dismissed

ITA 3582/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Raj Kumar, CA &For Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 143(3)Section 14ASection 68

findings in assessment year 2015-16 on the very issue (page 7 para 4) whilst holding the loans/advances in question as unexplained cash credits u/s 68 of the Act. 5. That being the case, learned counsel representing assessee takes us to page 3 in the paper book wherein this tribunal

Adhunik Akshat Udyog Pvt. Ltd., Dumka vs. ACIT, Circle-3(1), Deoghar

In the result, the appeal of the assessee is allowed

ITA 163/RAN/2025[12-13]Status: DisposedITAT Ranchi10 Oct 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.163/Ran/2025 Assessment Year: 2012-13 Adhunik Akshat Udyog Pvt. Ltd……………............................……….……Appellant Industrial Area, Babupur, Muffasil Thana Dumka, Jharkhand – 814101. [Pan: Aabca4896Q] Vs. Acit, Circle-3(1), Deoghar…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri Sushil Pransukha, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 28, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 11.03.2025 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2012–13. 2. Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For Ay 2012–13 Declaring Total Income Of ₹2,57,551. The Case Was Reopened Under Section 147 On The Ground That The Assessee Had Raised Share Capital & Share Premium From Certain Entities, Whose Financial Capacity & Genuineness Of Investment Remained Unexplained. During Assessment, The Ao Noted That The Assessee Had Introduced Share Capital Of ₹37,50,000 From The Following Four Private Limited Companies:

Section 131Section 147Section 250Section 68

entities.” Since the assessee failed to produce directors and furnish further documents, the AO treated the entire sum of ₹37,50,000 as unexplained cash credit under section 68, and completed the assessment at ₹40,07,551. 3. On appeal, the CIT(A) sustained the addition. He held that ... considered the rival submissions and perused the record. The central issue is whether the sum of ₹37,50,000 can be treated as unexplained cash credit under section 68 of the Act in AY 2012–13. From the balance sheet of the assessee as on 31.03.2011, we find that

Golden Goenka Commerce Pvt. Ltd., Kolkata vs. ACIT Circle-2(1), Jamshedpur

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

ITA 11/RAN/2024[2011-12]Status: DisposedITAT Ranchi10 Oct 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

Section 131Section 143(3)Section 147Section 148Section 68

assessee had failed to discharge the onus under section 68 of the Act. Accordingly, the entire amount of ₹4.73 crores was treated as unexplained cash credit and added to the income of the assessee. Apart from the above, the AO also disallowed set-off of certain losses against capital gains

Abid Mustafa Khan, Nagpur vs. ITO Ward-2(3), Nagpur

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

ITA 502/NAG/2025[2015-16]Status: DisposedITAT Nagpur10 Oct 2025AY 2015-16

Bench: Shri Pavan Kumar Gadaleabid Mustafa Khan, 301, Mayfair Residency, Raj Nagar Opp. Green Park, Nagpur 440 013, ……………. Appellant Maharashtra. Pan – Aqipk9595G V/S Income Tax Officer ……………. Respondent Ward–3(2), Nagpur, Maharashtra. Assessee By: Shri K.K. Thakkar. A.R. Revenue By :Shri Surjit Kumar Saha.Sr.Dr

For Appellant: Shri K.K. Thakkar. A.RFor Respondent: Shri Surjit Kumar Saha.Sr.DR

Section 142(1)Section 148Section 148ASection 151Section 69A

void ab initio." 05. Learned AO erred in making addition u/s. 69A though in order every where this addition is mentioned as "Unexplained Cash Credits". 06. Learned CIT (A) erred in dismissing the appeal solely on the grounds of delay and without adjudicating case on merits. 07. Learned ... Assessing Officer found that the explanations does not satisfy the sources of cash deposits in the bank account and was treated as unexplained cash credit u/sec 69A of the Act and assessed the total income of Rs.46,95,000/–, and passed order u/sec 147 r.w.s. 144 of the Act dated

Kishore Bhagwandas Nagdeo, Washim vs. ITO Ward-2, Washim

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

ITA 395/NAG/2025[2017-18]Status: DisposedITAT Nagpur10 Oct 2025AY 2017-18

Bench: Shri Pavan Kumar Gadalekishore Bhagwandasnagdeo, Ice An Spice, Opp. Shivaji High School ……………. Appellant Washim 444 505, Maharashtra. Pan–Acvpn7049R V/S Income Tax Officer ……………. Respondent Ward–2, Washim, Maharashtra. Assessee By: Shriharish Bhoneja.A.R. Revenue By :Shri Surjit Kumar Saha.Sr.Dr

For Appellant: ShriHarish Bhoneja.A.RFor Respondent: Shri Surjit Kumar Saha.Sr.DR

Section 44ASection 68

following grounds of appeal:– ”1. On the facts and in the circumstances of the case the addition of Rs.5,50,000/-as unexplained cash credit u/s 68 is bad in law. 2. On facts and in the circumstances of the case the learned AO erred in invoking the provisions ... facts and the circumstances of the case the learned CIT(A) erred in sustaining the addition of Rs.5,50,000/- as unexplained Cash Credits u/s 68 of the Income Tax Act, 1961. 4. On the facts and the circumstances of the case the learned CIT(A) erred in not accepting

Princess Infra & Development LLP, Kota vs. ACIT-Central Circle-Kota, Kota

In the result, both the appeals of the assesseeare allowed for statistical purposes as indicate hereinabove

ITA 859/JPR/2025[2018-19]Status: DisposedITAT Jaipur10 Oct 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 144Section 153B(1)(b)Section 153CSection 56(2)(X)Section 68

addition under section 68 of the Act on account of unsecured loan of Rs.8,10,00,000/- after treating the same as unexplained cash credits. 6. That on the law and in the facts and in the circumstances of the case the learned Assessing Officergrossly erred in making an addition ... account of partners capital introduced of Rs.10,00,000/- after treating the same as unexplained cash credits.’’ ITA NO. 859/JPR/2025 - A.Y. 2018-19 ‘’1. That on the facts and circumstances of the case and in law, the id. CIT(Appeal) has grossly erred in dismissing the appeal on ground

Princess Infra & Development LLP, Kota vs. ACIT-Central Circle-Kota, Kota

In the result, both the appeals of the assesseeare allowed for statistical purposes as indicate hereinabove

ITA 858/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 144Section 153B(1)(b)Section 153CSection 56(2)(X)Section 68

Pramila Agarwal, Jaipur vs. The Income Tax Officer Ward-2(5), Jaipur

In the result, the appeal of the assessee is allowed

ITA 531/JPR/2025[2011-12]Status: DisposedITAT Jaipur10 Oct 2025AY 2011-12

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 10(38)Section 147Section 148Section 68

Cash credit (Share transactions) - Assessment year 2014-15 - Assessing Officer treated LTCG disclosed by assessee on sale of shares as unexplained cash credit on basis that assessee had introduced his own unaccounted money by way of bogus LTCG - Tribunal held that since assessee had produced all relevant documentary evidence

Rakesh Jayantibhai Patel, Ahmedabad vs. Income Tax Officer, Ward - 5(3)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1301/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Vimal Desai, ARFor Respondent: Shri Sudhakar Verma, Sr.DR

Section 115BSection 147Section 58Section 68

addition sustained by the Ld. CIT(A) is not justified. Accordingly, we direct to delete the remaining addition made on account of unexplained cash credit under section 68 of the Act. 8. In the result, the appeal of the assessee is allowed. The order is pronounced in the open Court

Ashok Amarnath Agrawal, Vadodara vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, appeal of the assessee in ITA No

ITA 1078/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri B.P. Srivastava, Sr DR

Section 10(38)Section 132Section 147Section 250Section 271ASection 68

Limited, an alleged accommodation entry provider. The Assessing Officer disallowed the claim and treated the entire sale proceeds of Rs.23,81,100/- as unexplained cash credits under section 68 of the Act. 5. Aggrieved by the order of the Assessing Officer, the assessee filed appeal before

Ashok Amarnath Agrawal, Vadodara vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, appeal of the assessee in ITA No

ITA 1077/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri B.P. Srivastava, Sr DR

Section 10(38)Section 132Section 147Section 250Section 271ASection 68

Shyamprasad Reddy Gaddam, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 196/HYD/2024[2014-15]Status: DisposedITAT Hyderabad10 Oct 2025AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 196/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Shyamprasad Reddy Vs. Dcit, Gaddam, Central Circle-3(3), Hyderabad. Hyderabad. Pan: Aetpg9117P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Sri Gurpreet Singh, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals)- 11, Hyderabad, Dated 02/02/2004, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 144 R.W.S 153A Of The Income Tax Act, 1961 (For Short, “Act”), Dated 12/12/2019 For The Assessment Year 2014-15. 2 Shyamprasad Reddy Gaddam Vs. Dcit

For Appellant: Sri P. Murali Mohan Rao, CAFor Respondent: Sri Gurpreet Singh, Sr. AR

Section 132Section 132(4)Section 144Section 153ASection 250Section 68Section 69Section 69A

search proceedings): Rs. 35,16,93,754/-; (ii) unexplained investment towards stamp duty and other charges: Rs. 15,00,000/-; and (iii) unexplained cash credits U/s. 68 of the Act in his three bank accounts: Rs. 80,53,411/-. 6. Aggrieved, the assessee carried the matter in appeal before ... erred in law and facts of the case in recharacterizing the addition of Rs. 80,53,411/- made by the AO as an unexplained cash credit under Section 68 of the Act as an addition under Section 69A of the Act. Elaborating on his contention, the Ld. AR submitted that

Hotel Preethi International Pvt. Ltd., Nilgiris vs. ITO, Corporate Ward-2, Coimbatore

In the result, the appeals filed by the assessee are allowed for

ITA 2555/CHNY/2025[2017-18]Status: DisposedITAT Chennai10 Oct 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Shri S. Sridhar (Erode), AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 147Section 68

parte for the AY 2017-18 and made total addition of Rs.5,43,21,954/- towards undisclosed interest, unexplained credits u/s. 68 and unexplained cash credits u/s.68 and Id. AO also completed the assessments ex-parte for the for AY 2018-19 by best judgment assessment u/s.147 r.w.s.144 r.w.s 144B

Hotel Preethi International Pvt. Ltd., Nilgiris vs. ITO, Corporate Ward-2, Coimbatore

In the result, the appeals filed by the assessee are allowed for

ITA 2554/CHNY/2025[2018-19]Status: DisposedITAT Chennai10 Oct 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Shri S. Sridhar (Erode), AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 147Section 68

Girish Karamshi Dedhia, Mumbai vs. DCIT, Circle 15(1), Mumbai

ITA 4553/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Bhadresh Doshi, ARFor Respondent: Shri Swapnil Choudhary, CIT-DR

Section 14ASection 250Section 40Section 68Section 69A

side accepting the source of cash deposit and on the other side, he is making the cash deposit as unexplained cash credit which is self-contradictory. The Assessing Officer following the Circular dated 08-11-2016, which is not applicable since Para (e) of the Circular deals with the cases

Income Tax Officer-1(1)(3), Mumbai vs. Golden Express Private Limited, Mumbai

ITA 3039/MUM/2025[2018]Status: DisposedITAT Mumbai10 Oct 2025

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Vimal Punmiya &For Respondent: Shri Arun Kanti Datta, CIT-DR

Section 142(1)Section 143(3)Section 145(3)Section 148Section 148ASection 250Section 68

Forex Pvt. Ltd. the AO had himself estimated income at 0.5% of turnover instead of treating the entire turnover as unexplained cash credit. The CIT(A) upheld the rejection of books of accounts by the AO. The CIT(A) however held that it would not be justifiable to treat