Transfer Pricing Adjustment Softened for Long-Standing ECB Loans

Gulbrandsen Technologies (India) Private Limited Vs Additional/Joint/Deputy /ACIT/ITO-National Faceless Assessment Centre (ITAT Ahmedabad) Fixed ECB Rate Accepted: ITAT Ahmedabad Resolves Transfer Pricing Dispute by Benchmarking at 5.35% ITAT Ahmedabad “D” Bench, in Gulbrandsen Technologies (India) Pvt. Ltd. vs ACIT (NFAC) (ITA No. 160/Ahd/2022, AY 2017-18, order dated 23-12-2025), dealt with a transfer pricing adjustment on interest paid on ECB loans obtained from Associated Enterprises. The assessee had availed ECB in FY 2005-06 at a fixed interest rate of 5.50%, duly approved by RBI and...