Details of the Order

  • Order Issuing Authority: Income Tax Appellate Tribunal, "F" Bench, Mumbai
  • Order Date: 15th September 2026
  • Date of Receipt by Company: 22nd September 2026
  • Assessment Year: 2016-17
  • Act & Section: Income Tax Act, 1961, Section 254(1)
  • Outcome: Appeal decided in favor of the company.

Background of the Case

  • The case originated from a search action under Section 132 of the Income Tax Act, carried out on 24th March 2021.
  • For AY 2016-17, the Assessing Officer framed an assessment under Section 153A.
  • An addition of ₹6,79,64,220 was made, comprising:
  • ₹6,37,10,000 treated as unexplained cash credit under Section 68 in respect of unsecured loans from four lender entities.
  • ₹42,54,220 being disallowance of interest paid on such loans under Section 37.
  • This addition was upheld by the CIT(A)-11, Pune vide order dated 8th November 2024.
  • The company subsequently preferred an appeal before the ITAT.

ITAT's Findings and Ruling

  • The ITAT accepted the company's submissions and dropped the proceedings.
  • The tribunal held that the company had duly discharged the onus of proving:
  • The identity and creditworthiness of the lenders.
  • The genuineness of the loan transactions under Section 68.
  • It was also noted that the loans, along with interest, were repaid during the year itself.
  • Final Ruling: The tribunal dropped the entire demand of ₹3,96,75,696 and deleted the addition of ₹6,79,64,220, allowing the company's appeal.

Financial Impact

  • Quantifiable Impact: The order results in the deletion of a tax demand of ₹3,96,75,696 (comprising tax and consequential interest) for AY 2016-17.
  • Contingent Liability: The company currently discloses a contingent liability of ₹3,96,75,696. This liability will stand extinguished once the order is given effect by the concerned income tax department.
  • Operational Impact: The company does not foresee any material impact on its financial, operational, or other activities.

Company Registered Office

B-2 & B-3, B Wing, 3rd Floor, Ashar IT Park, Road No.16-Z, Wagle Industrial Estate, Thane - 400604.