Indore, 10.12.2025 : The National Company Law Tribunal, Indore Bench has ruled that self-prepared interest calculations, including Excel sheets, cannot be relied upon to admit interest claims in insolvency proceedings unless there is clear contractual or statutory proof. The Tribunal clarified that while interest can form part of “financial debt” under the Insolvency and Bankruptcy Code, 2016, it must be supported by a contractual agreement or documentary evidence reflected in the records of the corporate debtor.
The ruling was delivered by Judicial Member Brajendra Mani Tripathi and Technical Member Man Mohan Gupta while deciding an application filed by Jayshree Agnihotri under Section 60(5) of the IBC in the corporate insolvency resolution process of Pushp Ratna Realty Pvt. Ltd.
The applicant had filed her claim in June 2025 in Form C, asserting that she was a financial creditor and seeking admission of both principal and interest on an unsecured loan allegedly advanced to the corporate debtor. The Resolution Professional admitted the principal amount as it was reflected in the corporate debtor’s books of account but rejected the interest component, which was claimed at the rate of 18 percent, due to lack of supporting documentation.
Challenging this decision, the applicant argued before the Tribunal that interest is expressly included within the definition of “financial debt” under Section 5(8) of the IBC. She also claimed discrimination, seeking parity with another unsecured creditor whose interest liability was recorded in the balance sheet of the corporate debtor. To substantiate her claim, she relied mainly on a self-prepared Excel sheet showing interest calculations.
The Resolution Professional opposed the plea, submitting that there was no loan agreement, memorandum, payment ledger, or statutory record establishing any obligation on the part of the corporate debtor to pay interest to the applicant. It was argued that under the IBBI (CIRP) Regulations, 2016, claims must be verified strictly on the basis of the corporate debtor’s books of account and supporting records.
Accepting this position, the Tribunal referred to Regulations 13 and 14 of the CIRP Regulations and reiterated that verification of claims must rest on documentary evidence available in the corporate debtor’s records. The Bench observed that self-prepared calculations or arguments based on parity with other creditors cannot replace proof such as loan agreements, payment ledgers, or balance sheet entries acknowledging interest liability.
The Tribunal also rejected the parity argument, holding that interest liability is contractual in nature and cannot be claimed merely because interest was admitted in the case of another creditor. It noted that no interest had ever been paid to the applicant, even prior to the commencement of the CIRP, and that she had failed to establish any contractual or documentary basis for claiming interest.
In these circumstances, the NCLT held that the Resolution Professional had acted within his statutory mandate in admitting only the principal amount reflected in the corporate debtor’s books. Finding no illegality or infirmity in the rejection of the interest component, the Tribunal dismissed the application seeking admission of interest and revision of the resolution plan.
