← 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

Sita Ram Pansari, Transport Nagar Kuju vs. Income Tax Officer, Ramgarh Cantt

The appeals of the assessee are allowed for

ITA 126/RAN/2024[2017-2018]Status: DisposedITAT Ranchi09 Oct 2025AY 2017-2018

Bench: Shri Sonjoy Sarma, Jm & Shri Ratnesh Nandan Sahay, Am (Through Hybrid Mode) आयकर अपील सं./Ita Nos.123-126/Ran/2024 (निर्धारण वर्ा / Ayrs :2013-14, 2014-2015, 2015-16 & 2017-18) Sita Ram Pansari, Vs. Ito Ramgarh Transport Nagar, Main Road, Kuju, Jharkhand-825316 स्थायी लेखा सं./Pan No. : Ajppp 3351 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Akash Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Khubchand T Pandya Sr.Dr सुनवाई की तारीख / Date Of Hearing : 02/09/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : All The Above Captioned Appeals Are Filed By The Assessee Against The Separate Orders, All Dated 20.02.2024 Passed By Ld.Cit(A), Patna-3, Against Which The Assessee Preferred Appeals Before The Tribunal. 2. Since The Issues Involved In These Appeals Are Common Except The Figures & Assessment Years In Question, Therefore, All The Four Appeals Are Heard Together & Decided By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.123/Ran/2025 For A.Y.2013-2014. 4. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Or Profession Of Coal Trading Under E-Auction

For Appellant: Shri Akash Agarwal, ARFor Respondent: Shri Khubchand T Pandya Sr.DR
Section 115BSection 142(1)Section 147Section 148Section 68

Rs.34 lakhs and added to the total income of the assessee. Similarly, another sum of Rs.1,88,98,978/- found to be unexplained cash credit u/s.68 of the Act and added to the total income of the assessee u/s.68 of the Act along with Section 115BBE ... lakhs, which has already been deleted by the ld. CIT(A) and another is relating to addition of Rs.1,88,98,978/- as unexplained cash credit u/s.68 of the Act, where relief was granted to the assessee to the extent of Rs.34,55,500/- but remaining sum of Rs.1

Sita Ram Pansari, Transport Nagar Kuju vs. Income Tax Officer, Ramgarh Cantt

The appeals of the assessee are allowed for

ITA 125/RAN/2024[2015-2016]Status: DisposedITAT Ranchi09 Oct 2025AY 2015-2016

Bench: Shri Sonjoy Sarma, Jm & Shri Ratnesh Nandan Sahay, Am (Through Hybrid Mode) आयकर अपील सं./Ita Nos.123-126/Ran/2024 (निर्धारण वर्ा / Ayrs :2013-14, 2014-2015, 2015-16 & 2017-18) Sita Ram Pansari, Vs. Ito Ramgarh Transport Nagar, Main Road, Kuju, Jharkhand-825316 स्थायी लेखा सं./Pan No. : Ajppp 3351 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Akash Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Khubchand T Pandya Sr.Dr सुनवाई की तारीख / Date Of Hearing : 02/09/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : All The Above Captioned Appeals Are Filed By The Assessee Against The Separate Orders, All Dated 20.02.2024 Passed By Ld.Cit(A), Patna-3, Against Which The Assessee Preferred Appeals Before The Tribunal. 2. Since The Issues Involved In These Appeals Are Common Except The Figures & Assessment Years In Question, Therefore, All The Four Appeals Are Heard Together & Decided By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.123/Ran/2025 For A.Y.2013-2014. 4. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Or Profession Of Coal Trading Under E-Auction

For Appellant: Shri Akash Agarwal, ARFor Respondent: Shri Khubchand T Pandya Sr.DR
Section 115BSection 142(1)Section 147Section 148Section 68

Rs.34 lakhs and added to the total income of the assessee. Similarly, another sum of Rs.1,88,98,978/- found to be unexplained cash credit u/s.68 of the Act and added to the total income of the assessee u/s.68 of the Act along with Section 115BBE ... lakhs, which has already been deleted by the ld. CIT(A) and another is relating to addition of Rs.1,88,98,978/- as unexplained cash credit u/s.68 of the Act, where relief was granted to the assessee to the extent of Rs.34,55,500/- but remaining sum of Rs.1

Sita Ram Pansari, Transport Nagar Kuju vs. Income Tax Officer, Ramgarh

The appeals of the assessee are allowed for

ITA 124/RAN/2024[2014-2015]Status: DisposedITAT Ranchi09 Oct 2025AY 2014-2015

Bench: Shri Sonjoy Sarma, Jm & Shri Ratnesh Nandan Sahay, Am (Through Hybrid Mode) आयकर अपील सं./Ita Nos.123-126/Ran/2024 (निर्धारण वर्ा / Ayrs :2013-14, 2014-2015, 2015-16 & 2017-18) Sita Ram Pansari, Vs. Ito Ramgarh Transport Nagar, Main Road, Kuju, Jharkhand-825316 स्थायी लेखा सं./Pan No. : Ajppp 3351 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Akash Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Khubchand T Pandya Sr.Dr सुनवाई की तारीख / Date Of Hearing : 02/09/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : All The Above Captioned Appeals Are Filed By The Assessee Against The Separate Orders, All Dated 20.02.2024 Passed By Ld.Cit(A), Patna-3, Against Which The Assessee Preferred Appeals Before The Tribunal. 2. Since The Issues Involved In These Appeals Are Common Except The Figures & Assessment Years In Question, Therefore, All The Four Appeals Are Heard Together & Decided By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.123/Ran/2025 For A.Y.2013-2014. 4. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Or Profession Of Coal Trading Under E-Auction

For Appellant: Shri Akash Agarwal, ARFor Respondent: Shri Khubchand T Pandya Sr.DR
Section 115BSection 142(1)Section 147Section 148Section 68

Rs.34 lakhs and added to the total income of the assessee. Similarly, another sum of Rs.1,88,98,978/- found to be unexplained cash credit u/s.68 of the Act and added to the total income of the assessee u/s.68 of the Act along with Section 115BBE ... lakhs, which has already been deleted by the ld. CIT(A) and another is relating to addition of Rs.1,88,98,978/- as unexplained cash credit u/s.68 of the Act, where relief was granted to the assessee to the extent of Rs.34,55,500/- but remaining sum of Rs.1

Sita Ram Pansari, Transport Nagar vs. Income Tax Officer, Ramgarh

The appeals of the assessee are allowed for

ITA 123/RAN/2024[2013-14]Status: DisposedITAT Ranchi09 Oct 2025AY 2013-14

Bench: Shri Sonjoy Sarma, Jm & Shri Ratnesh Nandan Sahay, Am (Through Hybrid Mode) आयकर अपील सं./Ita Nos.123-126/Ran/2024 (निर्धारण वर्ा / Ayrs :2013-14, 2014-2015, 2015-16 & 2017-18) Sita Ram Pansari, Vs. Ito Ramgarh Transport Nagar, Main Road, Kuju, Jharkhand-825316 स्थायी लेखा सं./Pan No. : Ajppp 3351 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Akash Agarwal, Ar राजस्व की ओर से /Revenue By : Shri Khubchand T Pandya Sr.Dr सुनवाई की तारीख / Date Of Hearing : 02/09/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : All The Above Captioned Appeals Are Filed By The Assessee Against The Separate Orders, All Dated 20.02.2024 Passed By Ld.Cit(A), Patna-3, Against Which The Assessee Preferred Appeals Before The Tribunal. 2. Since The Issues Involved In These Appeals Are Common Except The Figures & Assessment Years In Question, Therefore, All The Four Appeals Are Heard Together & Decided By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.123/Ran/2025 For A.Y.2013-2014. 4. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Or Profession Of Coal Trading Under E-Auction

For Appellant: Shri Akash Agarwal, ARFor Respondent: Shri Khubchand T Pandya Sr.DR
Section 115BSection 142(1)Section 147Section 148Section 68

Rs.34 lakhs and added to the total income of the assessee. Similarly, another sum of Rs.1,88,98,978/- found to be unexplained cash credit u/s.68 of the Act and added to the total income of the assessee u/s.68 of the Act along with Section 115BBE ... lakhs, which has already been deleted by the ld. CIT(A) and another is relating to addition of Rs.1,88,98,978/- as unexplained cash credit u/s.68 of the Act, where relief was granted to the assessee to the extent of Rs.34,55,500/- but remaining sum of Rs.1

Krrish Distributors Pvt. Ltd, Patna vs. ITO, Ward-2(1), Patna

The appeal of the assessee is allowed for statistical purposes

ITA 367/PAT/2025[2011-12]Status: DisposedITAT Patna09 Oct 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.367/Pat/2025 Assessment Year: 2011-12 Krrish Distributors Pvt. Ltd….………. …………………....Appellant 54, Harihar Apartment, East Boring Canal Road, Patna, Bihar- 800001.. [Pan: Aadck3250E] Vs. Ito, Ward-2(1), Patna…....…..……………..………………….…..... Respondent Appearances By: Shri D. V. Pathy, Sr. Adv., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 08, 2025 Date Of Pronouncing The Order : October 09, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Is Directed By The Assessee Against The Order Dated 21.08.2024 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Is A Private Limited Company. In The Case Of The Assessee The Assessment Was Reopened Under Section 148 Of The Act On The Ground That, During The Year Under Consideration, The Assessee Had Received Unsecured Loans Amounting To ₹27,35,000, For Which No Satisfactory Explanation Or Supporting Evidence Was Furnished During The Re-Assessment Proceedings. The Assessing Officer Completed The Assessment Under Section 147 Read

Section 144Section 147Section 148Section 250

Distributors Pvt. Ltd with Section 144, determining the total income at ₹32,50,320 after making an addition of ₹27,35,000 as unexplained cash credit. 3. The learned CIT(A) dismissed the appeal ex parte, observing that despite several opportunities, the assessee failed to comply with the notices