Fusion Finance Limited (FFL) has announced a significant victory in a tax appeal. The Income Tax Appellate Tribunal (ITAT), New Delhi, has dismissed appeals filed by the Income Tax Officer (ITO) for Assessment Year (AY) 2020-21 and AY 2021-22. For AY 2020-21, the ITAT dismissed the ITO's appeal against an order passed under section 250 of the Income Tax Act, 1961. This order pertains to a total demand of ₹16,62,03,454, which includes tax liability of ₹9,54,65,663 and interest liability of ₹7,07,37,791. The original issue involved allegations of non-deduction/lower deduction of tax on interest payments made to foreign NCD holders, where the company was treated as a "deemed assessee in default". The company had previously filed an appeal on July 12, 2024, which resulted in the deletion of the demand raised under section 201 of the Act. The ITO's subsequent appeal on September 29, 2025, challenging the CIT(A)'s order, has now been dismissed. Similarly, for AY 2021-22, the ITAT has dismissed the ITO's appeal regarding a total demand of ₹11,18,43,066, comprising a tax liability of ₹7,10,23,805 and interest liability of ₹4,08,19,261. The details of the alleged violation are similar to the previous assessment year. The company's appeal on July 12, 2024, was decided in its favor, leading to the deletion of the demand. The ITO's appeal filed on September 29, 2025, has also been dismissed by the ITAT. The company received the orders on May 29, 2026, and became aware of them through a routine review of the ITAT website, as intimation was not received via email. FFL has stated that these outcomes will have no impact on its financials, operations, or other activities.
