The reported ITAT Delhi ruling in Shriganesh Kirana (P) Ltd. v. ACIT says the company discharged its burden under Section 68 for a ₹1.40 crore unsecured loan from LVS Financial Services Pvt. Ltd. The Tribunal relied on the combined evidence of the lender’s identity and creditworthiness and the transaction’s genuineness. The available report does not establish the final outcome of the separate interest, Section 69C or reopening issues, so it would be premature to say that every disputed addition was deleted.
What the appeal concerned
The appeal, ITA No. 2536/Del/2026, concerned assessment year 2020-21. The reported order is dated 30 September 2026; the appeal was heard on 14 July 2025 and arose from a CIT(A)-30, New Delhi order dated 14 February 2026.
According to the assessment narrative reported in the case text, the assessment was reopened on information associated with a 17 November 2021 search involving Galaxy Group and alleged entry providers. The Assessing Officer treated a ₹1,40,00,000 loan received from LVS Financial Services Pvt. Ltd. as an accommodation entry and added it as unexplained cash credit under Section 68. That characterization was the assessment’s allegation; it should not be presented as an independently established fact or as the Tribunal’s finding.
What the Tribunal found about the loan
Shriganesh Kirana said it had taken an unsecured business loan from LVS and later repaid it. Its submissions described LVS as a company engaged in non-banking finance and referred to an RBI registration certificate.
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The reported order lists a range of documents in the company’s record, including:
- the loan agreement, lender confirmation and lender ledger;
- the lender’s income-tax return and audited financial statements;
- bank statements for both lender and borrower;
- company records; and
- ledgers relating to repayment.
The Tribunal stated that the loan had been received through an account-payee cheque. It considered the evidence together and concluded that the assessee had established the creditor’s identity and creditworthiness and the genuineness of the transaction. On that record, it said the Section 68 burden had been discharged.
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What this means for Section 68 loan disputes
The ruling is about the evidence in this appeal, not a blanket rule that a bank transfer or subsequent repayment settles every Section 68 dispute. For a disputed loan, the record described here illustrates the kinds of questions that can matter: who the lender is, whether the lender had financial capacity, and whether the transaction is genuine. The reported decision supports discussing those elements together; it does not establish that any one document or banking-channel payment is sufficient on its own.
The Tribunal also relied on DCIT v. Shomit Finance Ltd., ITA No. 8486/Del/2025, dated 5 June 2026, which involved an advance from the same lender. Secondary reporting names Real Innerspring Technologies (P.) Ltd. v. ACIT and Capital Infra Projects (P.) Ltd. v. DCIT among related authorities. The available accounts do not support a more detailed account of those decisions’ holdings.
Other disputed amounts and issues
The assessment included amounts beyond the principal loan addition. The reported case text gives these figures:
| Issue | Amount | What the report establishes |
|---|---|---|
| Unsecured loan treated as unexplained cash credit under Section 68 | ₹1,40,00,000 (₹1.40 crore) | The Tribunal said the assessee discharged its Section 68 burden on the evidence before it. |
| Interest expense disallowed | ₹1,44,956 | Reported as an assessment disallowance; the available account does not establish the Tribunal’s final disposition. |
| Alleged commission added under Section 69C | ₹4,20,000 | Reported as calculated at 3% of the loan; the available account does not establish the Tribunal’s final disposition. |
The reported materials also identify objections to reopening and jurisdiction. They do not provide a verified final disposition of those objections or of the interest and Section 69C issues. The conclusion about the Section 68 loan should not be extended to those separate matters.
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How to read the reported outcome
The case-text page used for the report is from a legal reporting database, not an official ITAT-hosted order. Although the reported text states the Tribunal’s conclusion on the Section 68 burden, the complete final order is needed to verify the disposition of the other grounds and any exact procedural wording. The case should therefore be described narrowly: on the reported record, the Tribunal found the evidence sufficient to discharge the Section 68 burden for the loan.
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