Unexplained cash credits under section 68 require proof of lender genuineness, creditworthiness, and source of funds before acceptance.

Section 68 addition for loans as unexplained cash credits could not be conclusively decided on the existing record because the lenders' genuineness, creditworthiness, and the source of cash deposits in their bank accounts remained unverified. Although confirmations and section 133(6) materials were filed, the directors of the lending companies did not comply with summons and were not produced despite opportunity, leaving the assessee's onus undischarged on the material facts. The matter was therefore remanded to the Assessing Officer for fresh adjudication after production of the directors and explanation of the cash deposits.

---

---

Issues: Whether the addition made under section 68 on account of loans treated as unexplained cash credits was sustainable, or the matter required fresh examination by the Assessing Officer.

Analysis: The loans were received from two corporate lenders, but the bank statements showed cash deposits immediately before issue of cheques. Summons issued to the directors were not complied with, and the assessee also failed to produce them despite opportunity. Mere filing of confirmations and documents under section 133(6) did not, on these facts, discharge the onus where the genuineness of the transactions and the source of cash deposits remained unproved. Since the core controversy turned on verification of the lenders, their creditworthiness, and the source of cash deposits, further factual inquiry was necessary.

Conclusion: The addition was not finally sustained or deleted; the matter was remanded to the Assessing Officer for fresh adjudication after the assessee produces the directors of the lenders and explains the source of cash deposits.

---