M/S. SOUTH WEST PINNACLE EXPLORATION LIMITED,GURUGRAM vs. ACIT, CIRCLE-24(1), NEW DELHI

ITA 4076/DEL/2025Status: DisposedITAT Delhi21 January 2026AY 2014-15Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No.4076/Del/2025 (Assessment Year: 2014-15) M/s. South West Pinnacle Exploration Limited, vs. ACIT, Circle 24 (1), Plot No.6, 4th Floor, Sector 44, New Delhi. Gurugram - 122 003 (Haryana). (PAN : AAKCS3608R) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri I.P. Bansal, Advocate Shri Vivek Bansal, Advocate REVENUE BY : Shri Manish Gupta, Sr. DR Date of Hearing : 25.11.2026 Date of Order : 21.01.2026 ORDER PER S. RIFAUR1 pages
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What did the Tribunal hold?

The Tribunal held that the unsecured loans were genuine as they were received and repaid through banking channels with interest, supported by documentary evidence. However, the addition for belated employee PF/ESIC contributions was dismissed as the assessee did not press the issue and it was covered by a Supreme Court decision.

What were the facts?

The assessee company, engaged in exploration services, received unsecured loans from corporate entities. The Assessing Officer (AO) made additions for belated employee PF/ESIC contributions and for the genuineness of unsecured loans based on an investigation report. The CIT(A) upheld the PF/ESIC addition and made enhancements to the unsecured loan addition.

What were the issues?

The primary issue was the genuineness of unsecured loans and the addition for belated employee PF/ESIC contributions. The Tribunal also considered enhancements made by the CIT(A).

Which sections of the Income-tax Act were involved?

Section 68,Section 115BBE,Section 2(24)(x),Section 36(1)(va)

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Income Tax Appellate Tribunal, DELHI BENCHES ‘G’: NEW DELHI.

For Appellant: Shri I.P. Bansal, Advocate, Shri Vivek Bansal, Advocate
For Respondent: Shri Manish Gupta, Sr. DR
Hearing: 25.11.2026

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

The assessee has filed appeal against the order of the Learned Commissioner of Income Tax (Appeals)-24, New Delhi [“Ld. CIT (A)”, for short] dated 17.06.2025 for the Assessment Year 2014-15. 2. At the outset, ld. AR of the assessee submitted that the issues involved in the present appeal are squarely covered by various decisions and he heavily relied upon the decision of the coordinate Bench in the case of Real Innerspring Technologies Pvt. Ltd. vs. ACIT (2025) 174

2 taxmann.com 1130 (Delhi-Tribunal), in which one of us is the author of the order.

3.

Further ld. AR of the assessee submitted brief facts and his submissions in the p

The order continues below.

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