Key Quantitative Figures
- Total disallowances quashed: ₹64,14,963
- Breakdown: ₹62,67,024 towards CENVAT Credit written off and ₹1,47,939 towards Employees' Provident Fund contribution
- Original tax demand: ₹28,94,598
- Assessment Year: 2016-17
Dates of Action
- Appellate Order Date: November 04, 2026
- Date of Receipt: November 04, 2026
- Original Assessment Order Date: February 22, 2024
- Disclosure Date: November 05, 2026
Parties Involved
- Appellant: Span Divergent Limited (formerly Span Diagnostics Ltd.)
- Appellate Authority: Commissioner of Income Tax (Appeals)-12, Ahmedabad
- Original Assessing Authority: Assistant Commissioner of Income Tax, Central Circle 2(3), Ahmedabad
Nature of Proceedings
The company had filed an appeal before the Commissioner of Income Tax (Appeals)-12, Ahmedabad against the assessment order dated February 22, 2024. The Assessing Officer had made additions/disallowances aggregating to ₹64,14,963 comprising ₹62,67,024 towards CENVAT Credit written off and ₹1,47,939 towards Employees' Provident Fund contribution.
Outcome of Appeal
The Commissioner of Income Tax (Appeals) held that the assessment proceedings were unsustainable in the absence of identified incriminating material supporting the additions made by the Assessing Officer. The appellate authority accordingly quashed the entire assessment order dated February 22, 2024.
Financial Impact
The order provides relief to the Company by quashing the assessment order involving additions/disallowances of ₹64,14,963. The consequential impact on the tax demand of ₹28,94,598 will be given effect to as per applicable tax procedures. The disclosure explicitly states: "No operational impact."
Status of Appeal
The appeal has been partly allowed in favor of the company.