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The reported ITAT Delhi ruling in Shriganesh Kirana (P) Ltd. v. ACIT concerns a ₹1.40 crore unsecured loan from LVS Financial Services Pvt. Ltd. for assessment year 2020–21. The Tribunal said the company had discharged its burden under Section 68 by producing evidence that established the lender’s identity and creditworthiness and the genuineness of the transaction. That finding rests on the combined record in this appeal; it does not mean a bank transfer or later repayment alone proves every loan is genuine.
What the appeal concerned
The reported order, dated 30 September 2026, concerns ITA No. 2536/Del/2026 and an appeal from an order of CIT(A)-30, New Delhi, dated 14 February 2026. The appeal was heard on 14 July 2025.
The assessment for AY 2020–21 was reopened on the basis of information associated with a 17 November 2021 search involving the Galaxy Group and alleged entry providers. The Assessing Officer treated ₹1,40,00,000 received from LVS Financial Services Pvt. Ltd. as an accommodation entry and added it as unexplained cash credit under Section 68. That was the assessment’s allegation, not a finding that the Tribunal ultimately made about the transaction.
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Shriganesh Kirana said it had received an unsecured business loan from LVS and later repaid it. The assessment also disallowed ₹1,44,956 of interest and made a ₹4,20,000 addition under Section 69C, describing it as alleged commission calculated at 3% of the loan amount.
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The reported Tribunal excerpt addresses the Section 68 burden for the loan. It does not establish the final disposition of the interest disallowance, the Section 69C addition, or the company’s objections to reopening and jurisdiction. Those issues should not be described as allowed, deleted, or sustained on the basis of the available excerpt.
What evidence the Tribunal considered
The reported order lists documentation from both sides of the transaction, including:
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- A loan agreement, lender confirmation and ledger.
- The lender’s income-tax return and audited financial statements.
- Bank statements for the lender and borrower.
- Company records and repayment-related ledgers.
- The assessee’s submissions describing LVS as a non-banking finance company and referring to an RBI registration certificate.
The Tribunal stated that the loan was received through an account-payee cheque. It considered the evidence as a whole sufficient to establish the creditor’s identity and creditworthiness and the genuineness of the transaction. On that record, it concluded that the assessee had discharged its burden under Section 68.
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It is a finding on the record in this appeal
The decision supports a narrow takeaway: the Tribunal found the collection of lender, financial, loan, banking and repayment documents in this case sufficient to meet the Section 68 burden. It is not a blanket rule that a loan routed through a bank account, or repaid later, must be accepted as genuine.
Search-related allegations are not the same as proof of this loan
The assessment’s accommodation-entry characterization arose from search-related information. The reported excerpt’s stated conclusion turns on whether the assessee’s evidence established identity, creditworthiness and genuineness. The excerpt does not support a broader categorical claim about when search information or third-party material is enough in other cases.
Related authority mentioned in the report
The reported text says the Tribunal relied on DCIT v. Shomit Finance Ltd., ITA No. 8486/Del/2025, dated 5 June 2026, which involved an advance from the same lender. A secondary report also identifies Real Innerspring Technologies (P.) Ltd. v. ACIT and Capital Infra Projects (P.) Ltd. v. DCIT among related authorities. The available excerpts do not establish the detailed holdings of those other cases, so they should not be treated here as broader rules.
What taxpayers can take from the evidence record
For a taxpayer responding to a Section 68 question about an unsecured loan, the case illustrates why the documentary record may need to address more than the movement of funds. The materials described in the order covered who the lender was, its financial position, the loan terms, the banking trail and accounting records relating to repayment. The Tribunal’s conclusion was based on that combined evidence and the particular record before it.
Limits of the reported outcome
The case text used for this report is from a legal reporting database, not an official ITAT-hosted order. The reported order date is 30 September 2026, and the reporting is dated 3 October 2026. The available excerpt does not verify the final result on the interest, Section 69C or reopening grounds; those outcomes require the complete final order. No verbatim judicial quotation is reproduced here.
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