Services to overseas group entities not “FTS” under Section 9(1)(vii) & DTAA: Karnataka HC

PCIT Vs Goldman Sachs Services Pvt. Ltd. (Karnataka High Court) Karnataka HC dismisses Revenue’s appeals – Services to overseas group entities not “FTS” under Section 9(1)(vii) & DTAA The Revenue filed four appeals u/s 260A against a common order of the ITAT, Bengaluru Bench dated 29.04.2022 in IT(IT)A Nos. 365–369/Bang/2020 relating to A.Ys. 2014-15, 2015-16, 2016-17 & 2018-19, in the case of Goldman Sachs Services Pvt. Ltd. The core issue before the Court was whether the ITAT erred in holding that payments made by the assessee to its overseas affiliates for certain support ...