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)
173-182 and pages 228-243 of the PB-Vol I as sample.
3.5 The assessee submitted that, the reimbursement of salary cost was on 'cost-to-cost' basis, and did not include any element of profit or mark-up, and therefore, such payments were not chargeable to tax under the provisions of the act.
3.6 Without prejudice
