PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S GOLDMAN SACHS SERVICE PVT LTD

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ITA/123/2024HC KarnatakaKAHC01014958202423 September 2025Bench: S.G.PANDIT,K. V. ARAVIND3 pages
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What did the High Court hold?

The High Court noted that connected appeals arising from the same common ITAT order had already been disposed of by a previous order of the Court. Therefore, this appeal was also disposed of in terms of that prior order.

What were the facts?

The Revenue filed an appeal before the High Court against an order of the Income Tax Appellate Tribunal (ITAT). The appeal was against a common order passed by the ITAT for the assessment year 2017-18.

What were the issues?

The primary issue was the appeal filed by the Revenue against the ITAT's order. The resolution of the appeal was based on the disposal of other connected appeals.

Which sections of the Income-tax Act were involved?

Section 260-A

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:38175-DB ITA No. 123 of 2024

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF SEPTEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL NO.123 OF 2024 BETWEEN: 1. PRINCIPAL COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE.

2.

THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1 (1), KORAMANGALA BANGALORE. …APPELLANTS (BY SRI. E.I. SANMATHI, ADV.)

AND: M/S. GOLDMAN SACHS SERVICE PVT. LTD., WING A, WING B AND GROUND FLOOR TO 6TH FLOOR WING C HELIOS BUSINESS PARK 150 OUTER RING, KADUBEESANAHALLI BANGALORE -560103 PAN: AACCG2435N REP. BY ITS DIRECTOR. …RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADV.)

THIS APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 29.04.2022 PASSED IN IT(TP)A NO. 368/BANG/2020 FOR THE ASSESSMENT YEAR 2017-18, PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED 29.04.2022 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, ‘A’ BENCH, BANGALORE, AS SOUGHT FOR, IN THE

Digitally signed by NANJUNDACHARI Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2025:KHC:38175-DB ITA No. 123 of 2024

RESPONDENT-ASSESSEE’S CASE, IN APPEAL PROCEEDINGS IN IT(TP)A NO. 368/BANG/2020 FOR A.Y 2017-18 (ANNEXURE A) AND GRANT SUCH OTHER RELIEF AS DEEMED FIT, IN THE INTEREST OF JUSTICE.

THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.G.PANDIT AND HON'BLE MR. JUSTICE K. V. ARAVIND

ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT)

Heard learned senior standing counsel Sri.E.I.Sanmathi for appellants/Revenue and learned counsel Smt.Tanmayee Rajkumar for the respondent. Perused the entire appeal papers.

2.

This appeal is filed against the common order dated 29.04.2022 in IT(IT)A.No.368/Bang/2020 passed by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘the Tribunal’) for the assessment year 2017-18 (Annexure-A).

3.

During the course of hearing, it is brought to the notice of this Court that ITA filed against the

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HC-KAR NC: 2025:KHC:38175-DB ITA No. 123 of 2024

connected appeals of the ITAT are disposed of by this Court by order dated 03.09.2025 in ITA.No.121/2024 and connected appeals.

4.

In view of disposal of the other writ appeals which were part of the common order, this appeal would also stands disposed of in terms of the order dated 03.09.2025 in ITA.No.121/2024 and connected appeals.

In view of disposal of the appeal, I.A.No.1/2025 would not survive for consideration.

Sd/- (S.G.PANDIT) JUDGE

Sd/- (K. V. ARAVIND) JUDGE

NC CT:bms List No.: 1 Sl No.: 4

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