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Case lawConcepts › Burden of proof for cash credits (section 68)

Burden of proof for cash credits (section 68)

The officer says my loan is unexplained — what exactly do I have to prove?

The officer says my loan is unexplained — what exactly do I have to prove?

Under section 68 the initial burden is on you to explain the nature and source of any sum credited in your books, and courts have read that as requiring proof of three things: the identity of the creditor, his creditworthiness, and the genuineness of the transaction. Only once all three are established prima facie does the onus shift to the department, and since the Finance Act 2022 the explanation must in most cases also cover the creditor's own source.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

Section 68 provides that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about its nature and source, or the explanation offered is not in the opinion of the Assessing Officer satisfactory, the sum may be charged to income-tax as the income of the assessee of that previous year.

The section speaks only of "nature and source". The three-ingredient test — identity, creditworthiness, genuineness — is judicial gloss, and it is the framework every assessment order and every appellate order uses. Identity means the creditor is a real, identifiable person or entity. Creditworthiness means that person had the financial capacity to advance what he advanced. Genuineness means the transaction actually happened as described and is not a paper entry.

The Supreme Court in PCIT v. NRA Iron & Steel Pvt. Ltd. set out the onus in these terms: the assessee is under a legal obligation to prove the receipt of share capital or premium to the satisfaction of the Assessing Officer, and only when the three ingredients are established prima facie is the department required to undertake any further exercise. Once that threshold is crossed, the burden shifts and it is for the revenue to show that the sum is nonetheless the assessee's income. The court drew on Kale Khan Mohammad Hanif, Roshan Di Hatti, CIT v. Oasis Hospitalities and CIT v. N.R. Portfolio.

The critical practical point from NRA Iron & Steel is that routing money through banking channels does not by itself establish creditworthiness. A bank statement showing an immediately preceding deposit of the same amount proves the mechanics of the transfer, not the capacity of the payer. Documents such as PAN, return acknowledgement and confirmation letters go to identity; they are necessary but not sufficient.

The statute has been progressively tightened on the "source of source" question. A proviso inserted by the Finance Act 2012 provides that where a closely held company receives share application money, share capital or share premium, the explanation is not satisfactory unless the resident person in whose name the credit is recorded also offers an explanation about the nature and source of that sum and the Assessing Officer finds it satisfactory. The Finance Act 2022 extended the same requirement to loans and borrowings, with effect from 1 April 2023, that is from assessment year 2023-24. A further proviso excludes credits from a venture capital fund or venture capital company referred to in section 10(23FB).

So the year matters. For a loan credited before assessment year 2023-24, the older line of reasoning — that the assessee's burden is confined to the transaction between himself and the creditor, as in Nemi Chand Kothari — has force. For a loan credited from assessment year 2023-24 onwards, the statute itself requires the creditor's source to be explained.

A reply under section 68 therefore has to be built as an evidence file rather than an argument. For each credit: who, proved by identity documents and confirmation; what capacity, proved by the creditor's own financial statements, returns and bank record showing where his funds came from; and what actually happened, proved by the banking trail, the loan agreement or share application, interest paid, TDS deducted, and the repayment record. Where the year attracts the source-of-source proviso, add the creditor's explanation of his own source.

Why it matters

Most section 68 additions are lost not on law but on gaps in the file, so the reply should be organised credit by credit against the three ingredients rather than written as a general denial. Establishing all three prima facie is what shifts the onus, and once shifted the officer has to bring material of his own rather than rely on your failure. Whether you must also explain the creditor's source depends on the assessment year, so check that before conceding the point.

What to do

Where people go wrong

Unsettled, or not pinned down. The two sources I fetched give different effective dates for the Finance Act 2012 proviso on share capital (one puts it at assessment year 2012-13, the other at the following year), so I have named the amending Act without fixing the date; the Finance Act 2022 date of 1 April 2023 was consistent across both. The departmental text of section 68 I retrieved carried no amendment footnotes. There is also unresolved tension in the case law on how far the department may probe layers of source in years before the statutory provisos applied.

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.