SGD PHARMA INDIA PRIVATE LIMITED, ,MAHABUBNAGAR vs. DCIT, CIRCLE -3 (1), HYDERABAD

ITA 130/HYD/2022Status: DisposedITAT Hyderabad21 January 2026AY 2017-1814 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The tribunal ruled that the assessee's benchmarking of interest on ECB loans at LIBOR + 500/450 basis points was at arm's length, following previous decisions. The issue of disallowance under Section 43B was remitted to the Assessing Officer for fresh verification due to a potential double disallowance.

What were the facts?

The assessee, SGD Pharma India Private Limited, filed appeals for Assessment Years 2017-18 and 2018-19. The key dispute revolved around the transfer pricing adjustment made for interest on External Commercial Borrowings (ECBs) and a disallowance under Section 43B.

What were the issues?

Benchmarking of interest on ECB loans at arm's length and double disallowance of expenses under Section 43B.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 92CA,Section 43B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘A‘ Bench, Hyderabad

Before: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurwala, CA
For Respondent: Smt. K. Haritha, CIT(DR)
Hearing: 17/12/2025

Per Madhusudan Sawdia, A.M.: Both these appeals are filed by M/s. SGD Pharma India Private Limited (“the assessee”), feeling aggrieved by the separate final assessment orders passed by the Learned Assessing Officer (“Ld. AO”) under section 143(3) read with sections 144C(13) of the Income Tax Act, 1961 (“the Act") dated 25.02.2022 and 27.07.2022 for A.Y 2017-18 & 2018-19 respectively in pursuance of the directions issued by the Learned Di

The order continues below.

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