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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

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Massimo Enterprise, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1111/SRT/2024[2013-14]Status: DisposedITAT Surat22 Aug 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

erred in deleting the addition of Rs.74,87,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed ... erred in deleting the addition of Rs.15,88,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Anupa Jignesh Amin, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1109/SRT/2024[2013-14]Status: DisposedITAT Surat22 Aug 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

erred in deleting the addition of Rs.74,87,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed ... erred in deleting the addition of Rs.15,88,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Jignesh Mahesh Amin, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1108/SRT/2024[2015-16]Status: DisposedITAT Surat22 Aug 2025AY 2015-16

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

erred in deleting the addition of Rs.74,87,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed ... erred in deleting the addition of Rs.15,88,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed

Assistant Commissioner of Income Tax, Central Circle-3, Surat vs. Jignesh Mahesh Amin, Surat

In the result, appeal of Revenue is dismissed and additional ground raised by the assessee is also dismissed

ITA 1107/SRT/2024[2014-15]Status: DisposedITAT Surat22 Aug 2025AY 2014-15

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1107 & 1108/Srt/2024 Assessment Years: 2014-15 & 2015-16 (Hybrid Hearing) Assistant Commissioner Of Jignesh Mahesh Amin बनाम/ Income-Tax, Central Circle- 418, Royal Trading Tower, Nr. Vs. 3, Surat, 5Th Floor, Aayakar Ratan Cinema, Salabatpura, Surat- Bhawan, Majura Gate, 395 003 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aajpa 2349 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1109/Srt/2024 Assessment Year: 2013-14 Assistant Commissioner Of Anupa Jignesh Amin बनाम/ Income-Tax, Central Circle- B-19, Ashirwad Residency Near Vs. 3, Surat, 5Th Floor, Aayakar China Gate, City Light, Surat-395 Bhawan, Majura Gate, 017 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acspa 6502 F (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.1111/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Assistant Commissioner Of Massimo Enterprise बनाम/ Income-Tax, Central Circle- Fp No.139, Orleaans, Near Sosyo Vs. 3, Surat, 5Th Floor, Aayakar Circle, Udhna Magdalla Road, Bhawan, Majura Gate, Surat-395 007 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aavfm 0143 M (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 250Section 68

erred in deleting the addition of Rs.74,87,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed ... erred in deleting the addition of Rs.15,88,000/- made by the AO u/s 68 of the I.T. Act on account of unexplained cash credit in the form of accommodation entries observing that the appellant had repaid the entire loans in the subsequent years which is not disputed

Charan Singh, Vpo Topra Kalan vs. ITO, Ward-1, Yamunanagar

In the result, appeal of the assessee stands allowed

ITA 85/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh22 Aug 2025AY 2017-18

Bench: Shri Sanjay Gargआयकरअपीलसं./Ita No.85/Chd/2025 िनधा"रणवष" / Assessment Year : 2017-18 बनाम Charan Singh The Ito, S/O. Sh. Mansa Ram Ward-1, 257, Vpo-Topra Kalan, Yamunagar Tesil Jagadhri Yamunagar Haryana 135 133 Haryana – 135 133 "थायीलेखासं./Pan No. Dkaps 0306 G अपीलाथ"/Appellant ""थ"/Respondent ( Physical Hearing ) िनधा""रतीकीओरसे/Assessee By : Sh. Vibhore Garg, Ca राज कीओरसे/ Revenue By : Sh. Vivek Vardhan, Addl.Cit, Sr.Dr सुनवाईकीतारीख/Date Of Hearing : 29/05/2025 उदघोषणाकीतारीख/Date Of Pronouncement : 22/08/2025 आदेश/Order The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 20/11/2024 Passed By The Ld. Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year (Ay) 2017-18. 2. The Assessee, In This Appeal, Is Aggrieved By The Action Of The Ld.Cit(A) In Confirming The Addition Of Rs.4,45,000/- Made By The Assessing Officer (Ao) On Account Of Unexplained Cash Credits In The Bank Account Of The Assessee During The Demonetization Period. The Ao During The Assessment Proceedings Noticed That There Was A Substantial Cash Deposit Of Rs.17,95,500/-In The Two Bank Accounts Of

For Appellant: Sh. Vibhore Garg, CAFor Respondent: Sh. Vivek Vardhan, Addl.CIT, Sr.DR

action of the Ld.CIT(A) in confirming the addition of Rs.4,45,000/- made by the Assessing Officer (AO) on account of unexplained cash credits in the bank account of the assessee during the demonetization period. The AO during the assessment proceedings noticed that there was a substantial cash deposit