DCIT 7(1)(1), MUMBAI vs. GOLDMAN SACHS (INDIA) SECURITIES P.TL, MUMBAI

ITA 1546/MUM/2015Status: DisposedITAT Mumbai17 February 2022AY 2010-1166 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee's appeal is partly allowed for statistical purposes, and the Revenue's appeal is dismissed. Specific findings on transfer pricing adjustments and ESOP expenses were upheld or modified.

What were the facts?

The case involves cross-appeals by the assessee and the revenue concerning the assessment year 2010-11. The primary dispute revolves around transfer pricing adjustments for investment advisory/support services, IT-enabled services, and broking services, as well as the allowability of Employee Stock Option Plan (ESOP) expenses.

What were the issues?

The key issues include the correctness of transfer pricing adjustments made by the TPO, the rejection of comparables, the method of computing ALP, and the allowability of ESOP expenses as a deduction.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(3),Section 37(1),Section 133(6),Section 234B,Section 234C

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Cases cited in this judgment(11)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “K”, MUMBAI

Before: MRS. DIVA SINGH & SHRI RIFAUR RAHMAN&

Hearing: 25.11.2021Pronounced: 17.02.2022

PER DIVA SINGH, J.M:

These are cross appeals filed by the Assessee and the Revenue pertaining to 2010-11 assessment year assailing the Goldman Sachs (India) Securities P.Ltd. V DCIT ITA NO.1115 & 1546/MUM/2015 (A.Y.2010-11) assessment order dated 28.01.2015 passed u/s 143(3) r.w.s.

144C(3) of the Income Tax Act, 1961 wherein the parties are

The order continues below.

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