ITAT asked AO to determine if payment for software service is FTS or Royalty

IN THE ITAT BANGALORE BENCH ‘A’ Goldman Sachs Services (P.) Ltd. Versus Deputy Director of Income-tax (International Taxation) IT APPEAL NOS. 196 & 197 (BANG.) OF 2011 [ASSESSMENT YEAR 2007-08] NOVEMBER 30, 2012 ORDER Jason P. Boaz, Accountant Member These two appeals are directed against the order of the Commissioner of Income Tax (Appeals)-IV, Bangalore dt.12.11.2010 for Assessment Year 2007-08. 2. The facts of the case, in brief are as under : 2.1 The assessee company M/s. Goldman Sachs & Services Pvt Ltd (hereinafter referred to as GSSPL), is in the bus...