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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

Income Tax Officer, I P Estate vs. Bansal Insulation Products Pvt Ltd., Okhla Delhi

In the result, appeal of the Revenue is partly allowed as

ITA 2892/DEL/2024[2013-14]Status: DisposedITAT Delhi30 Sept 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2892/Del/2024 िनधा"रणवष"/Assessment Year: 2013-14 Income Tax Officer, Vs. Bansal Insulation Products P. Ltd. C.R. Building, C-54/3, Okhla Industrial Area, I.P. Estate, Delhi. Phase-Ii, Delhi. Pan No.Aaacb5035F अपीलाथ" Appellant ""यथ"/Respondent & Co No.79/Del/2024 (Arising Out Of Ita No.2892/Del/2024) िनधा"रणवष"/Assessment Year: 2013-14 बनाम Bansal Insulation Products P. Ltd. Income Tax Officer, C-54/3, Okhla Industrial Area, Vs. C.R. Building, Phase-Ii, Delhi. I.P. Estate, Delhi. Pan No.Aaacb5035F अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 148ASection 68

proceedings before Investigation Wing, identity and genuineness of the transactions remained unproved and therefore the AO has rightly treated such transactions as an unexplained cash credits u/s 68 of the Act. Since the bogus entries taken by the assessee is nothing but equal amount of cash has been paid ... assessment order. Therefore, he strongly supported the order of the AO in treating Rs.8,31,15,488/- as an unexplained cash credit of the assessee. 3. On the other hand, the Ld. Counsel for the assessee strongly supported the orders of the Ld. CIT(Appeals). 4. Ld. Counsel

DCIT, Central Circle-7, New Delhi vs. Silver City, New Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1709/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmandcit, Central Circle 7, Vs. Silver City, 28-12-2813, 1St Floor, New Delhi. Gali No.20, Beadon Pura, Karol Bagh, New Delhi – 110 005. (Pan :Acrfs7187F) (Appellant) (Respondent) Assessee By : Ms. Ananya Kapoor, Advocate Shri Shashwat Bajpai, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 15.07.2025 Date Of Order : 30.09.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-24, Delhi [“Ld. Cit(A)”, For Short] Dated 21.03.2023 For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income On 30.10.2017 Declaring Total Income Of Rs.2,04,40,760/-. The Case Was Selected For Scrutiny Through Cass. Notices Under Section 143(2) Of The Income-Tax Act, 1961 (For Short ‘The Act’) Were Issued & Served Through Sped Post As Well As Through

For Appellant: Ms. Ananya Kapoor, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 133(6)Section 142(1)Section 143(2)Section 68

figure of sales has been considered as correct then there is no justification for making an addition of the same sales as unexplained cash credit u/s 68 of Income Tax Act. In view of the foregoing discussion and taking into consideration of all the facts and the circumstances