IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM &

MS PADMAVATHY S, AM I.T.A. No. 2062/Mum/2025 (Assessment Year: 2016-17) I.T.A. No. 2063/Mum/2025 (Assessment Year: 2021-22)

Goldman Sachs (Singapore) Pte, ACIT (International Tax)-2(3)(2), C/o Ernst & Young LLP, 14^th Floor, Room No. 610, 6^th Floor, The Ruby, 29 Senapati Bapat Marg, Kautilya Bhavan, C-41 to C-43, Vs.

Dadar West, Mumbai-400028. G B l o c k , B andra Kurla Complex, PAN: AAFCG0345N Bandra (East), Mumbai-400051.

Appellant) : Respondent Assessee / Appellant by : Shri Hiten Thakkar (Virtually Present), AR Revenue / Respondent by : Shri Krishna Kumar, Sr. DR Date of Hearing : 06.10.2025 Date of Pronouncement : 10.10.2025 O R D E R Per Padmavathy S, AM:

These appeals by the assessee are against the separate orders of the Commissioner of Income Tax (Appeals)-56, Mumbai [In short 'CIT(A)'] passed under section 250 of the Income Tax Act, 1961 (the Act) for Assessment Years (AY) 2016-17 & 2021-22 both dated 15.01.2025. The common issues contended by the assessee in both these appeals pertain to the denial of carry forward of brought forward capital losses of AY 2014-15.

2. The assessee is a company