GE overseas group companies having PE & DAPE in India, liable to tax in India

GE Energy Parts Inc Vs CIT (Delhi High Court) Conclusion: Assessee-GE group had carried out business through PE in India and GE India constituted DAPE in India for all overseas GE Group entities as LO were discharging vital responsibilities relating to finalization of commercial terms and a prominent involvement in the contract finalization process. The intricate nature of activities of GE India was carefully designed, where technical officials having varying degree of authority involved themselves – along with local managerial and technical employees, in contract negotiation, often into cor...