ITAT Allows Use of Extrapolated Data for Comparables With Different Year-End in ITeS Transfer Pricing Dispute Involving Goldman Sachs

In a transfer pricing dispute involving Goldman Sachs (in the ITES sector), the ITAT permitted the use of extrapolated data for comparable companies with different year-ends. The ruling acknowledged the practical difficulties in securing perfectly aligned comparables and endorsed interpolation to derive arm’s-length data. This approach ensures more reliable benchmarking for transfer pricing adjustments. By allowing such flexibility, the Tribunal enables a pragmatic solution to date misalignment challenges, supporting accurate and fair pricing arrangements across intercompany transactions while maintaining compliance with international tax norms. (Article summary)