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9 results for “disallowance”+ Section 44Dclear

Sorted by relevance

Mumbai44 Delhi42 Bangalore9 Kolkata4 Chennai3 Ahmedabad2 Dehradun2 Telangana1 Indore1 Nagpur1 Surat1

Key Topics

Section 201(1)32 Section 20132 Section 19516 Section 192(1)8 Deduction8 Double Taxation/DTAA8 Section 1322 Section 1482 Section 372 Section 147

GOPAL ANIL KUMAR,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the assessee is allowed

ITA 862/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Ms. Pooja Maru, A.RFor Respondent: Sri Balusamy N., D.R

Section 132Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 37Section 44ASection 68

2

Disallowance 28 to 44D 90,50,000 270A(9)(c) u/s 37 of IT Act 8 Unexplained 68 21,08,825 271AAC of credits the Act 9 Unexplained 68 96,90,000 271AAC of credits the Act 10 Business income 28 to 44D 40,25,068 270A(9)(c) 2,48,73,893/- Gopal Anil Kumar, Bengaluru Page

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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 365/BANG/2020[2012-13]Status: DisposedITAT Bangalore29 Apr 2022AY 2012-13

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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 367/BANG/2020[2013-14]Status: DisposedITAT Bangalore29 Apr 2022AY 2013-14

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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 369/BANG/2020[2014-15]Status: PendingITAT Bangalore29 Apr 2022AY 2014-15

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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 368/BANG/2020[2014-15]Status: DisposedITAT Bangalore29 Apr 2022AY 2014-15

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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 366/BANG/2020[2013-14]Status: DisposedITAT Bangalore29 Apr 2022AY 2013-14

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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 364/BANG/2020[2012-13]Status: DisposedITAT Bangalore29 Apr 2022AY 2012-13

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made

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)

section 9(1)(vii), the term 'fees for technical services' means any 'consideration' for rendering of managerial, consultancy or technical services. The Ld.AR submitted that, the remuneration and other administrative costs relating to seconded personnel was initially paid by overseas entity and these sums were reimbursed by the assessee. It was also submitted that, this arrangement was made