Sapphire Foods India Secures Favourable Tax Tribunal Ruling, Interest Liability Reduced by ₹16.79 Crores
Sapphire Foods India Limited has secured a major victory at the Income Tax Appellate Tribunal, with the Mumbai bench ruling in the company's favour regarding interest calculations under section 201(1A) of the Income Tax Act. The December 30, 2025 Order Giving Effect has reduced the company's interest liability from ₹17.04 crores to just ₹25.13 lakhs across seven assessment years (AY 2016-17, AY 2018-19 to AY 2023-24), delivering savings of approximately ₹16.79 crores.

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Sapphire Foods India Limited has achieved a significant legal victory in its tax dispute, with the Income Tax Appellate Tribunal (ITAT) delivering a favourable ruling that substantially reduces the company's interest liability under the Income Tax Act. The tribunal's decision, announced on November 7, 2025, has resulted in considerable financial relief for the quick service restaurant operator.
Tribunal Ruling Details
The Income Tax Appellate Tribunal, Mumbai, ruled in favour of Sapphire Foods, determining that interest under section 201(1A) of the Income Tax Act, 1961, should be restricted only up to the date of actual payment of tax. This interpretation significantly limited the company's exposure to interest charges on Tax Deducted at Source (TDS) matters.
The Assessing Officer (TDS) subsequently passed the Order Giving Effect (OGE) on December 30, 2025, implementing the tribunal's decision across multiple assessment years.
Financial Impact
The tribunal's ruling has delivered substantial financial benefits to Sapphire Foods across seven assessment years:
| Parameter | Amount |
|---|---|
| Assessment Years Covered | AY 2016-17, AY 2018-19 to AY 2023-24 (7 years) |
| Original TDS Liability | ₹17,04,10,490 |
| Revised Interest Liability | ₹25,13,273 |
| Total Savings | ₹16,78,97,217 |
The dramatic reduction from ₹17.04 crores to ₹25.13 lakhs represents a saving of approximately ₹16.79 crores for the company.
Legal Background
The current development follows the company's earlier intimation dated June 26, 2025, regarding the receipt of an order under section 250 from the Office of the Commissioner of Income Tax, Appeal Addl/JCIT(A), Ranchi. Sapphire Foods had subsequently filed an appeal at the Income Tax Appellate Tribunal in Mumbai challenging the original assessment.
Regulatory Compliance
Sapphire Foods has disclosed this development under Regulation 30 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, ensuring transparency with stakeholders regarding material legal proceedings. The company confirmed that the litigation does not involve key management personnel, promoters, or ultimate persons in control, and no settlement terms or compensation payments were required.
This favourable tribunal ruling provides significant financial relief to Sapphire Foods and resolves a long-standing tax dispute spanning multiple assessment years, potentially improving the company's cash flow position and reducing contingent liabilities.
Historical Stock Returns for Sapphire Foods
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +3.94% | +3.94% | +3.36% | -21.82% | -22.73% | +6.08% |









































