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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

Devraj Vishwasrao Jadhav, Pune vs. Income Tax Officer, Ward-3, Satara

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

ITA 2213/PUN/2024[2015-16]Status: DisposedITAT Pune23 Sept 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / .Ita No.2213/Pun/2024 धििेंारण वर्ा /Assessment Year: 2015-2016 Devraj Vishwasrao Ito, Ward-3, Satara Jadhav, R. No. 06, S. No. 24, Vs. Dreams Rhythm, Opposite Talathi Office, Bavdhan, Pune-411021 Maharashtra Pan-Aebpj6968F अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Dr. Prayag Jha Department By: Shri Ramnath P Murkunde Date Of Hearing: 23-09-2025 Date Of Pronouncement: 08-09-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 11.09.2024 Which Is Arising Out Of Order Passed U/S 147 Of The Act Dated 14.03.2023. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. The Ld Cit(A) Erred In Not Considering The Arguments & Submissions Made By The Assessee & Dismissing All The Grounds Taken In Appeal. 2. The Ld Cit(A) Erred In Not Appreciating That The Ld Assessing Officer Had Not Served On The Assessee The Statutory Notice Under Section 143(2) Of The It Act & Therefore, The Impugned Order Was Passed Without Jurisdiction.

For Appellant: Dr. Prayag JhaFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 147Section 148Section 148ASection 250Section 68Section 69A

record placed before us. We observe that during the course of assessment proceedings Ld. AO has made various additions including the addition for unexplained cash credit u/s 68 of the Act at Rs. 80,11,889/- and Rs. 74,44,000/- addition for unexplained money

ACIT, CC - 3(4), Kolkata vs. Rameswara Infrastructures Ltd, Kolkata

In the result, the appeal filed by the revenue is dismissed and 11

ITA 2692/KOL/2024[2019-20]Status: DisposedITAT Kolkata22 Sept 2025AY 2019-20

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2019-20 Acit, Central Circle-3(4), Kolkata.….……………….……….……….……Appellant Vs. Rameswara Infrastructures Ltd ………………………….....……...…..…..Respondent 19A, Sarat Bose Road Lr Sarani Kolkata-20. [Pan: Aaecr0505J] C.O. 19/Kol/2025 (In Ita Nos.2692 /Kol/2024) Assessment Year: 2019-20 Rameswara Infrastructures Ltd.….……………. ….……….……….……Cross-Objector 19A, Sarat Bose Road Lr Sarani Kolkata-20. [Pan: Aaecr0505J] Vs. Acit, Central Circle-3(4), Kolkata...………………………...…..…………….Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Assessee. Shri Raja Sengupta, Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : September 22, 2025 Order Per Pradip Kumar Choubey:

Section 139Section 139(1)Section 143(1)Section 143(2)Section 153ASection 153CSection 250Section 68

furnished by the assessee made the addition merely on the basis of a retracted statement of Sunil Kumar Murmuria treating the amount as unexplained cash credit. It is important to mention that Murmuria Promoters (P) Ltd. had opening balance of Rs.70,17,792/- and the entire transactions were made through ... these grounds, the appellant has agitated against the action of the AO in making an addition of Rs. 10,00,000/- as unexplained cash credit u/s 68 of the Act by treating unsecured loans received from companies controlled by Sunil Kumar Murmuria as bogus as well as the action