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“cash credit addition”

Cash Credits & Unexplained ItemsSection 68Section 6867 judgments

The decision most relied on for cash credit addition is Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd. (342 ITR 169), cited in 658 judgments on BharatTax.

Leading authorities on cash credit addition

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.

Umacharan Shaw & Bros. v. CIT
37 ITR 271 · 1959 · Supreme Court
567
citing judgments

An income tax assessment or addition cannot be sustained solely on the basis of suspicion, surmises, or conjectures, as strong suspicion does not amount to proof. The revenue authorities must rely on concrete evidence and material to frame an assessment.

Roshan Di Hatti v. CIT
107 ITR 938 · 1977 · Supreme Court
477
citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Kamdhenu Steel & Alloys Ltd.
361 ITR 220 · 2014 · High Court
328
citing judgments

When making an addition under section 68, the creditworthiness or financial strength of an investor contributing share capital or share application money can be proved by producing their bank statements showing sufficient balance for the investment. The Supreme Court dismissed the SLP against this decision.

CIT v. Devi Prasad Vishwanath Prasad
72 ITR 194 · 1969 · Supreme Court
272
citing judgments

If there is an unexplained cash credit, the Assessing Officer can treat it as the assessee's income, even when the income is finalized on an estimation basis, without proving its specific source. The onus then shifts to the assessee to prove that the income represented by the cash credit has already been taxed.

CIT v. N.R. Portfolio (P.) Ltd.
42 Taxmann.com 339 · 2014 · High Court
252
citing judgments

For cash credit additions under Section 68, establishing the 'identity' of a creditor requires more than just producing PAN or assessment particulars; it necessitates demonstrating their actual business operations, place of work, staff, and public recognition. This rigorous standard ensures the assessee proves the identity, creditworthiness, and genuineness of the transaction.

Judgments citing cash credit addition

Dy. Commissioner of Income Tax, Noida vs. M/S Rudra Buildwell Homes Pvt. Ltd, Delhi

ITA 602/DEL/2025[2016]Status: DisposedITAT Delhi29 Aug 2025

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Rudra Buildwell Homes Dcit, Central Circle-I, Noida Pvt. Ltd., 53, Okhla Phase, Delhi Pan: Aafcr6959P (Appellant) (Respondent) With C.O. No.106/Del/2025 [Arising Out Of Ita No.602/Del/2025] Assessment Year: 2016-17 M/S. Rudra Buildwell Vs. Dcit, Central Circle-I, Homes Pvt. Ltd., Noida A-66, Sector-63, Noida Pan: Aafcr6959P (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Agarwal, Itp Department By Sh. Rajesh Chandra, Cit(Dr) Date Of Hearing 12.08.2025 Date Of Pronouncement 29.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.602/Del/2025 & Assessee’S Cross Objection C.O. No. 106/Del/2025 For Assessment Year 2016-

Section 143(3)Section 148Section 148ASection 151Section 151(1)Section 151(2)

rival submissions. We are of the considered view that the learned CIT(A)’s foregoing detailed findings deleting the impugned section 68 unexplained cash credit addition warrant no interference on our part. Suffice to say, the assessee had admittedly received a sum of Rs.12.08 crores on 28.03.2016 coming from ... high court’s decision in Tax Appeal No.1180 of 2018 PCIT Vs. Gyscoal Alloys Ltd., dated 1st October, 2018 that section 68 unexplained cash credits addition in an instance involving group entities and directors etc. assessed in the same jurisdiction who satisfy the corresponding three limbs of identity, genuineness

DCIT, Delhi vs. Shalimar Corp. Limited, Mumbai

ITA 2502/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

Shalimar Corp Limited, Delhi vs. DCIT, Central Circle-30, New Delhi

ITA 2360/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

DCIT, Central Circle-30, New Delhi vs. Shalimar Corp. Ltd., Mumbai

ITA 2854/DEL/2022[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

DCIT, Central Circle-30, New Delhi vs. Shalimar Corp. Ltd., Mumbai

ITA 2853/DEL/2022[2013-14]Status: DisposedITAT Delhi31 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

Shalimar Corp Ltd, Lucknow vs. DCIT, Central Circle-30, New Delhi

ITA 2768/DEL/2022[2016-17]Status: DisposedITAT Delhi31 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

Shalimar Corp Ltd., Lucknow vs. DCIT, Central Circle-30, New Delhi

ITA 2767/DEL/2022[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

Shalimar Corp Ltd., Lucknow vs. DCIT, Central Circle-30, New Delhi

ITA 2766/DEL/2022[2014-15]Status: DisposedITAT Delhi31 Jul 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

Shalimar Corp Ltd., Lucknow vs. DCIT, Central Circle-30, New Delhi

ITA 2765/DEL/2022[2013-14]Status: DisposedITAT Delhi31 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

Shalimar Corp Ltd., Lucknow vs. DCIT Center Circle-30, Delhi

ITA 2764/DEL/2022[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating