GOLDEN AGRI RESOURCES (INDIA) PRIVATE LIMITED,DELHI vs. AU, NFAC, ITD, DELHI

ITTPA 48/DEL/2026Status: DisposedITAT Delhi30 September 2026AY 2022-2313 pages
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What did the Tribunal hold?

The Tribunal held that the core issue of benchmarking the assessee's international transactions for the purchase of traded goods has been examined by a Coordinate Bench in the assessee's own case for AY 2018-19, where the 'Other Method' using contemporaneous independent market quotations was accepted. The Tribunal found no material brought to its notice demonstrating a fundamental change in the nature of the impugned purchase transactions or the relevant functional profile compared to the earlier year. Therefore, it saw no sufficient reason to depart from the view taken in the assessee's own case on the core benchmarking issue. The Tribunal directed the Assessing Officer (AO)/TPO to determine the consequential arm's-length adjustment afresh in conformity with the Coordinate Bench's decision on the core issue. For residual and computational issues, including the selection/exclusion of comparables and grant of working-capital adjustment, the AO/TPO were directed to act strictly in accordance with the DRP's directions, after verifying the relevant data and affording the assessee a reasonable opportunity of being heard. The Tribunal expressly left undecided the specific comparable companies and the quantum of working-capital adjustment, deferring these to the AO/TPO as per DRP directions.

What were the facts?

The assessee, Golden Agri Resources (India) Private Ltd., engaged in trading edible oils and commodity futures, filed its return for AY 2022-23 declaring ₹20,03,72,589. The case was selected for scrutiny due to substantial international transactions with Associated Enterprises (AEs). The dispute centers on the benchmarking of purchases of traded edible oils from AEs. The assessee characterized its activity as a trader/distributor and adopted the 'Other Method' using contemporaneous market quotations. The Transfer Pricing Officer (TPO) rejected this, deeming the data unreliable, and adopted the Transactional Net Margin Method (TNMM), proposing an adjustment of ₹46,68,81,506. The Dispute Resolution Panel (DRP) upheld the TPO's authority to conduct a fresh benchmarking but directed adjustments to the comparable set and allowed working-capital adjustment in principle. The assessee appealed to the ITAT.

What were the issues?

1. Whether the Tribunal's decision in the assessee's own case for AY 2018-19, accepting the 'Other Method' based on market quotations for benchmarking purchases of traded goods, is applicable to AY 2022-23, considering the factual matrix of the current year. Assessee's Contention: The assessee argued that the 'Other Method' based on market quotations was accepted by the Tribunal in its own case for AY 2018-19 and should be followed for the current year. They also contended that the conditions for disturbing its determination of ALP were not satisfied. Revenue's Contention: The revenue, through the Ld. TPO and DRP, argued that the 'Other Method' was not appropriate as broker quotations might not fully account for all costs and variables. They also contended that the comparability position in the present year differed from AY 2018-19, justifying the adoption of TNMM and a fresh benchmarking exercise.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES “I” NEW DELHI

Before: MS. KAVITHA RAJAGOPAL & SMT. RENU JAUHRI

For Appellant: Shri Ajit Jain, AR &, Shri Vinamra Vij, AR
For Respondent: Shri Mahesh Kumar, CIT-DR
Hearing: 01.07.2026Pronounced: 30.09.2026

Per Kavitha Rajagopal, JM:

This appeal is filed by the assessee challenging the final assessment order of the Learned Assessing Officer [‘Ld. AO’ for short], dated 18.12.2025 passed u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (‘the Act', for short), pursuant to the direction of the Hon’ble Dispute Resolution Panel (Ld. DRP, for short), pertaining to the Assessment Years (‘A.Y.’ for short) , 2022-23. 2 IT(TP)A No.48/Del/2026 SA No.71/Del/2026

2.

The assessee company is engaged in the busines

The order continues below.

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