What is IDS Software Solutions P. Ltd. v. ITO authority for?

An Indian company that exercises control and supervision over a seconded employee and bears the salary cost is an economic employer. Such a company is not liable to withhold tax on the reimbursement of salary to the overseas company, thereby avoiding disallowance under Section 40(a)(i).

How many judgments cite IDS Software Solutions P. Ltd. v. ITO?

50 judgments on BharatTax cite IDS Software Solutions P. Ltd. v. ITO (122 TTJ 410), spanning 2016 to 2026.

Which sections of the Income Tax Act does IDS Software Solutions P. Ltd. v. ITO come up under?

It is most often cited in judgments turning on Section 10(B)(2), Section 12(4), Section 250, Section 250 of the Income Tax Act, Section 40(a)(i), Section 40(a)(i) of the Income Tax Act.

IDS Software Solutions P. Ltd. v. ITO (122 TTJ 410)

M/S. Goldman Sachs Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, International Taxation, Circle- 1(1), Bangalore

In the result, the appeal filed by the assessee for all the years under consideration stands allowed

ITA 363/BANG/2020[2011-12]Status: DisposedITAT Bangalore29 Apr 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 362 To 369 & 338 To 345/Bang/2020 Assessment Years : 2011-12 To 2014-15 & 2015-16 To 2018-19 M/S. Goldman Sachs Services Pvt. Ltd., The Deputy Wing A, Wing B & Commissioner Of Ground Floor To 6Th Floor Income Tax, Of Wing C, International Helios Business Park, Taxation, 150 Outer Ring, Vs. Circle 1 (1), Kadubeesanahalli, Bangalore. Bangalore – 560 103. Pan:Aaccg2435N Appellant Respondent Assessee By : Shri Sharath Rao, Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 09-03-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Appeals Are Filed By The Assessee Against Following Orders, Passed By The Ld. Dcit, International Taxation, Circle – 1(1), Bangalore Independently, Under Section 201(1) & 201(1A) Of The Act, For The Assessment Years Under Consideration As Under:

For Appellant: Shri Sharath Rao, CA

Section 192(1)Section 195Section 201Section 201(1)

….com190.  Decision of Authority of Advance Ruling in case of Cholamandalam MS General insurance Co.Ltd reported in (2009) 309 ITR 356.  Decision of coordinate bench of this Tribunal in case of IDS Software Solutions India Pvt.Ltd. vs. ITO reported in (2009) 122 TTJ 410.  Decision of coordinate bench of this Tribunal in case of Abbey Business Service Pvt.Ltd vs.DCIT reported in (2012) 23 taxmann.com 346.  Decision of Hon’ble Pune Tribunal in case of M/s. Faurecia Automative Holding vs.DCIT in ITA No,784/Pun/2015 by order dated 08/07/2019  Decision of Hon’ble Mumbai Tribunal in case of DIT vs. HCL Infosystems…

M/S. Goldman Sachs Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, International Taxation, Circle- 1(1), Bangalore

In the result, the appeal filed by the assessee for all the years under consideration stands allowed

ITA 362/BANG/2020[2011-12]Status: DisposedITAT Bangalore29 Apr 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 362 To 369 & 338 To 345/Bang/2020 Assessment Years : 2011-12 To 2014-15 & 2015-16 To 2018-19 M/S. Goldman Sachs Services Pvt. Ltd., The Deputy Wing A, Wing B & Commissioner Of Ground Floor To 6Th Floor Income Tax, Of Wing C, International Helios Business Park, Taxation, 150 Outer Ring, Vs. Circle 1 (1), Kadubeesanahalli, Bangalore. Bangalore – 560 103. Pan:Aaccg2435N Appellant Respondent Assessee By : Shri Sharath Rao, Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 09-03-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Appeals Are Filed By The Assessee Against Following Orders, Passed By The Ld. Dcit, International Taxation, Circle – 1(1), Bangalore Independently, Under Section 201(1) & 201(1A) Of The Act, For The Assessment Years Under Consideration As Under:

For Appellant: Shri Sharath Rao, CA

Section 192(1)Section 195Section 201Section 201(1)

….com190.  Decision of Authority of Advance Ruling in case of Cholamandalam MS General insurance Co.Ltd reported in (2009) 309 ITR 356.  Decision of coordinate bench of this Tribunal in case of IDS Software Solutions India Pvt.Ltd. vs. ITO reported in (2009) 122 TTJ 410.  Decision of coordinate bench of this Tribunal in case of Abbey Business Service Pvt.Ltd vs.DCIT reported in (2012) 23 taxmann.com 346.  Decision of Hon’ble Pune Tribunal in case of M/s. Faurecia Automative Holding vs.DCIT in ITA No,784/Pun/2015 by order dated 08/07/2019  Decision of Hon’ble Mumbai Tribunal in case of DIT vs. HCL Infosystems…

Expeditors International (India) Private Limited, New Delhi vs. ACIT Circle-7(1), New Delhi

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue are dismissed

ITA 20/DEL/2021[2014-15]Status: DisposedITAT Delhi30 Jul 2021AY 2014-15