GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024Status: DisposedITAT Bangalore23 February 2026Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal directed the AO/TPO to re-determine the Arm's Length Price (ALP) for ECB interest, considering the Hon'ble High Court's judgment on RBI's ceiling and the assessee's corroborative benchmarking analysis. The penalty proceedings and interest levies were dismissed as premature and consequential.

What were the facts?

The assessee, Goldman Sachs Services Private Limited, challenged the transfer pricing adjustment made on interest paid on External Commercial Borrowings (ECBs) for AY 2021-2022. The Assessing Officer (AO) made an upward adjustment of INR 62,88,86,271/-. The assessee argued that the AO erred in disregarding its benchmarking and not considering RBI's all-in-cost ceiling.

What were the issues?

Whether the transfer pricing adjustment on interest on ECBs was correctly determined by the AO/TPO, and if the RBI's all-in-cost ceiling and the assessee's benchmarking were properly considered.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144C(5),Section 92CA(3),Section 270A,Section 234A,Section 234B,Section 234C,Section 92C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, BANGALORE

[ Per Rahul Chaudhary, Judicial Member:

1.

The present appeal preferred by the Assessee is pertaining to Assessment Year 2021-2022 challenging Final Assessment Orders, dated 24/10/2024, passed by the Assessing Officer under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961[hereinafter referred to as ‘the Act’], as per the directions issued by [Dispute Resolution Panel (1)], Bengaluru [for short ‘DRP’], on 25/09/2024 under Section 144C(5) of the Act.

2.

The Assessee has raised

The order continues below.

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