Shipwaves Online loses tax appeal, ₹72.67 lakh demand upheld
- NFAC dismissed Shipwaves Online's appeal for AY 2024-25, upholding tax demand of ₹72.67 lakh
- Assessing officer disallowed gratuity expenses of ₹23.87 lakh and depreciation on intangibles of ₹2.21 crore
- Assessed total income rose to ₹5.28 crore against returned income of ₹2.83 crore
- Penalty proceedings under Section 270A(9) were not adjudicated as premature

*this image is generated using AI for illustrative purposes only.
Shipwaves Online Limited received an order from the National Faceless Appeal Centre (NFAC) dismissing its appeal against the income tax assessment for Assessment Year 2024-25. The appellate authority upheld a total tax demand of ₹72.67 lakh, confirming additions to the company's taxable income.
The order, dated September 29, 2026, was passed under Section 250 of the Income-tax Act, 1961. The dispute arose from assessment proceedings under Section 143(3) read with Section 144B, where the assessing officer disallowed specific expenses and increased the company's total income significantly above the returned figures.
Dispute details and financial impact
The NFAC upheld two primary additions made by the assessing officer: a disallowance of gratuity expenses amounting to ₹23.87 lakh and a disallowance of depreciation on intangible assets worth ₹2.21 crore. These adjustments raised the company's assessed total income to ₹5.28 crore, compared to the returned income of ₹2.83 crore.
| Particulars | Amount |
|---|---|
| Total Tax Demand | ₹72.67 lakh |
| Gratuity Expense Disallowance | ₹23.87 lakh |
| Depreciation Disallowance (Intangibles) | ₹2.21 crore |
| Assessed Total Income | ₹5.28 crore |
| Returned Income | ₹2.83 crore |
Penalty proceedings status
While the appellate authority confirmed the tax liability, it did not adjudicate on the initiation of penalty proceedings under Section 270A(9). The NFAC observed that the ground relating to penalty initiation was premature at this stage. Consequently, the final consequential tax liability, including applicable interest, will be determined in accordance with the provisions of the Income-tax Act, 1961.
What the numbers show
The disparity between the returned income of ₹2.83 crore and the assessed income of ₹5.28 crore highlights a significant divergence in accounting treatment, particularly regarding intangible asset depreciation. The disallowance of ₹2.21 crore in depreciation constitutes the majority of the added income, indicating that the company's aggressive amortization schedule for intangible assets was not accepted by the tax authorities.
Historical Stock Returns for Shipwaves Online
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -2.90% | -2.05% | -5.63% | +1.21% | -70.61% | -70.61% |
Will Shipwaves Online Limited pursue further legal recourse through the High Court or Supreme Court to challenge the ₹2.21 crore depreciation disallowance?
How might the pending adjudication of Section 270A penalty proceedings impact the company's total financial liability beyond the confirmed ₹72.67 lakh tax demand?
What changes to Shipwaves' future accounting policies for intangible asset amortization are likely to prevent similar disallowances in upcoming assessment years?


































