Self-Prepared Interest Calculations Cannot Substitute Contractual Proof In CIRP: NCLT Indore
The National Company Law Tribunal (NCLT) at Indore has held that self-prepared interest calculations, such as Excel sheets, cannot be the basis for admitting interest claims in insolvency proceedings without supporting contractual or statutory records. A coram of Judicial Member Brajendra Mani Tripathi and Technical Member Man Mohan Gupta said that interest can form part of financial debt...
The National Company Law Tribunal (NCLT) at Indore has held that self-prepared interest calculations, such as Excel sheets, cannot be the basis for admitting interest claims in insolvency proceedings without supporting contractual or statutory records.
A coram of Judicial Member Brajendra Mani Tripathi and Technical Member Man Mohan Gupta said that interest can form part of financial debt only when it is contractually agreed or clearly reflected in the corporate debtor's records.
The tribunal observed, “Self-prepared calculations (e.g., Excel sheets) or parity arguments do not substitute for proof like loan agreements, payment ledgers, or balance sheet entries acknowledging interest liability. Adjudicating Authority's consistently hold that financial debt under Section 5(8) IBC includes interest only if contractually agreed or evidenced.”
The ruling came from an application filed by Jayshree Agnihotri, a financial creditor in the CIRP of Pushp Ratna Realty Pvt Ltd. She submitted her claim in June 2025, seeking admission of both principal and interest on an unsecured loan. While the resolution professional (RP) admitted the principal amount reflected in the debtor's books of account, the interest component of eighteen percent was rejected due to lack of documentation.
Before the tribunal, the Agnihiotri argued that interest formed part of “financial debt” under Section 5(8) of the Insolvency and Bankruptcy Code and claimed parity with another unsecured creditor whose interest liability appeared in the company's balance sheet. She relied on a self-prepared excel sheet detailing interest calculations and contended that rejection of interest was discriminatory.
The RP opposed the plea, submitting that there was no loan agreement, memorandum, payment ledger, or statutory record evidencing any contractual obligation to pay interest to the applicant.
Agreeing with the RP, the tribunal held that under Regulations 13 and 14 of the IBBI (CIRP) Regulations, 2016, verification of claims must be grounded in the corporate debtor's books, supporting documents, and statutory records. The adjudicating authority observed that while Section 5(8) includes “interest, if any,” such interest must be contractually agreed or acknowledged by the corporate debtor.
The tribunal accordingly dismissed the application seeking admission of interest and revision of the resolution plan.
Case Title: Jayshree Agnihotri vs Hasti Mal Kacchara
Case Citation: 2026 LLBiz NCLT (IND) 16
Case Number: IA/378(MP)2025 in CP(IB)/26(MP)2024
For Applicant: Advocate Chiranjeevi Sahoo
For Respondent/RP: Advocate Ayushi J. Rajani
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