Set back to Nayara: ITAT Confirms ₹2,513 Crore Loss Disallowance, cites Inter-Corporate Deposits as Sham Due to Missing SPA and Fair Valuation

In a setback to Nayara Energy, the Income Tax Appellate Tribunal (ITAT) upheld the disallowance of ₹2,513 crore in losses related to inter-corporate deposits. ITAT found the transactions to be sham due to missing Share Purchase Agreements (SPA) and lack of fair valuation. Nayara claimed these deposits as business losses, but the tribunal ruled that the company failed to provide sufficient evidence, such as SPA and fair valuation reports, to substantiate its claims. The ruling reinforces the importance of proper documentation and transparency in inter-company transactions.