Key Quantitative Figures and Dates
- Appellate Order Date: November 04, 2026
- Date of Intimation to BSE: November 05, 2026
- Assessment Year in Question: 2017-18
- Amount of Addition Deleted: ₹1,50,000/-
- Related Donation Amount Mentioned: ₹1,00,00,000/- (made to All India Social Education Charitable Trust)
- Date of Original Assessment Order: February 26, 2024
Parties and Authorities Involved
- Listed Entity: Span Divergent Ltd. (Scrip Code: 524727)
- Appellate Authority: Commissioner of Income Tax (Appeals)-12, Ahmedabad
- Original Assessing Authority: Assistant Commissioner of Income Tax, Central Circle 2(3), Ahmedabad
- Counterparty Trust: All India Social Education Charitable Trust
- Signatory for the Company: Viral Desai, Managing Director (DIN: 00029219)
Details of the Action
The company had filed an appeal against an assessment order dated February 26, 2024, which was passed under Section 153C of the Income-tax Act, 1961. The Assessing Officer had alleged that the company incurred unexplained commission expenditure of ₹1,50,000/- in connection with a donation of ₹1,00,00,000/- made to All India Social Education Charitable Trust. Consequently, an addition of this amount was made under Section 69C of the Income-tax Act, 1961, and it was taxed under Section 115BBE.
The Commissioner of Income Tax (Appeals), vide its order dated November 04, 2026, has deleted the aforementioned addition of ₹1,50,000/-. It also held that the consequential taxation of this amount under Section 115BBE was unsustainable. The appeal was therefore partly allowed in favour of the company.
Financial and Operational Impact
As per the disclosure, the order is favourable to the company. The exact consequential tax impact, however, is stated to be determined upon giving effect to the appellate order. It is explicitly stated that there is no impact on the company's business operations.