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Case lawConcepts › How far the source-of-source enquiry can be pushed

How far the source-of-source enquiry can be pushed

The officer wants my lender's bank statements, and now his lender's. Where does this stop?

The officer wants my lender's bank statements, and now his lender's. Where does this stop?

The statute makes the person in whose name the credit is recorded explain his own source — one layer, not a chain — and only for the years and the credits the provisos cover. Beyond that the case law runs both ways: one line confines the enquiry to the transaction between the assessee and his creditor, another lets the officer look further where the file shows funds moving in a circle. Which line applies turns on the facts of the file, not on a general rule.

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.

Start with the section as it now stands, because the provisos do most of the work. The main limb of s.68 charges a sum found credited in the books where the assessee offers no explanation about its nature and source, or the explanation is not satisfactory in the officer's opinion.

The first proviso, inserted by the Finance Act 2022 with effect from 1 April 2023 and so applying from assessment year 2023-24, reads: "Provided that where the sum so credited consists of loan or borrowing or any such amount, by whatever name called, any explanation offered by such assessee shall be deemed to be not satisfactory, unless,—(a) the person in whose name such credit is recorded in the books of such assessee also offers an explanation about the nature and source of such sum so credited; and (b) such explanation in the opinion of the Assessing Officer aforesaid has been found to be satisfactory".

The second proviso, which came in earlier by the Finance Act 2012, does the same thing for a company in which the public are not substantially interested where the credit consists of share application money, share capital, share premium or any such amount, and requires the resident person in whose name the credit is recorded to explain his own source. A third proviso takes venture capital funds and venture capital companies out of both.

Read them literally and two things follow. First, the statutory burden is one step deep. It attaches to "the person in whose name such credit is recorded in the books of such assessee" and to no one behind him. Nothing in either proviso obliges the assessee to explain the source of that person's source. Second, the burden is selective — it bites on loans and borrowings only from assessment year 2023-24, and on share capital in a closely held company only from the year the 2012 proviso applies. For anything outside those descriptions, and for earlier years, the position is whatever the case law makes it.

On the case law there are two lines, and the editorial surveys collect them without resolving the conflict. The limiting line runs from Nemi Chand Kothari v. CIT (Gauhati), where the burden to prove genuineness and creditworthiness was held to remain confined to the transactions which have taken place between the assessee and the creditor, through Kinetic Capital Finance and MOD Creations in the Delhi High Court, and into the Bombay High Court's decision in Ami Industries. The most recent addition is PCIT v. KRBL Infrastructure Ltd (Delhi, November 2025), where the officer's material was against the lender's own purchases and the Court held that the assessment could not go into those purchases in the absence of anything connecting them to the assessee.

The permitting line runs the other way. Diza Holdings (Kerala) allowed the officer to ask whether the depositor had the source to make the deposit. N.R. Portfolio (Delhi) put it as a qualification rather than a rule — the doctrine of source of source cannot be applied universally, without reference to the factual matrix and the facts of each case. Mihir Kanti Hazra (Calcutta) treated the source of the source as a relevant enquiry. Rajmandir Estates (Calcutta), where the special leave petition was dismissed, went furthest: on a file showing matching credits into the subscribers' accounts shortly before their cheques were presented, the Court said the submission that a source-of-source enquiry is irrelevant did not appear to be correct.

The reconciliation that works in practice is N.R. Portfolio's: the deeper enquiry is not a standing entitlement, it is what an officer may do when the material in front of him shows the credit moving in a circle. Where the file shows an ordinary loan from a real lender with his own funds, the enquiry stops at the lender. Where it shows the money arriving with the lender days before it left him, the officer will be allowed to follow it, and an officer who does not may find the assessment revised under s.263 — which is what actually happened in Rajmandir Estates.

Where the lender is itself a company or a non-banking finance company, the practical question is not how many layers but what capacity is measured against. In DCIT v. ACE Infracity Developers the Delhi Tribunal held that where the lender is an NBFC and lending is its regular business, and no regulator has found any deficiency, identity is not in doubt; and that capacity is read off share capital, reserves, investments and long-term loans and advances rather than off revenue from operations. A lender whose business is lending will always have a large number of credits; that fact by itself is not a badge of an accommodation entry.

One digest reports the Tribunal referring to the provision by its Income-tax Act 2025 number, s.102. I have not verified that renumbering against the Act itself and it should be checked before use.

Why it matters

The reply you write depends on which of these two positions the file puts you in, and the first thing to fix is the assessment year — for most loans the statutory source-of-source burden simply does not exist before assessment year 2023-24, and a great many notices ignore that. Where it does exist, it stops at your creditor, and a demand for the creditor's creditor's records is a demand the statute does not make. Where the officer has material showing a circular flow, arguing that the enquiry is barred in principle will not work, and the answer has to be built on the facts instead.

What to do

Where people go wrong

Unsettled, or not pinned down. Nothing I fetched decides the question directly — no decision says in terms how many layers an officer may travel, or what the assessee must produce when the officer asks for the creditor's creditor. The citations for the limiting line other than Ami Industries and KRBL come from a single editorial survey and I have not read those judgments. The departmental text of s.68 I retrieved carried no amendment footnotes, so the effective dates come from commentary. The Income-tax Act 2025 numbering (s.102) is reported on one digest only and is unverified.

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.