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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Beena Pillai, Judicial Member, Bijayananda Pruseth, Accountant Member
Goldman Sachs International – Appellant
Versus
Assistant Commissioner of Income Tax (International Tax) 2(3)(2) – Respondent
| Table of Content |
|---|
| 1. facts of secondment and ao/drp taxation as fts. (Para 1 , 2) |
| 2. assessee arguments relying on prior rulings excluding fts. (Para 3) |
| 3. tribunal applies precedent: reimbursements not fts, indian employer controls. (Para 4) |
ORDER
Per Smt. Beena Pillai, JM:
Present appeal filed by assessee against the final assessment order dated 14.07.2025 passed u/s. 143(3) r.w.s. 144C(13) for A.Y. 2023-24 passed in pursuance of direction given by the DRP dated 27.06.2025 u/s. 144C(5) of the Income Tax Act, 1961 [hereinafter referred to as “the Act”]. The assessee raised the following grounds of appeal:
“1. The learned AO has on the facts and circumstances of the case and in law, erred in completing the assessment proceedings, where notice dated 11 February 2025 was issued by Income-tax officer-International Taxation- Ward 1(1) Bangalore and 4 March 2025 was issued by Income-tax officer- International Taxation-Ward 1(2), Bangalore and thereafter notices dated 11 March 2025 and 18 March 2025 under section 142(1) of the Act were issued by the learned AO without providing the basis of transfer of jurisdiction or without providing a copy of the order evidencing the transfer of jurisdiction
2
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