Reassessment quashed in absence of tangible material proving PE in India

Ge Steam Power Systems Vs ACIT (Delhi High Court) Delhi High Court held that reassessment under section 148 of the Income Tax Act cannot be sustained since there is no tangible material for forming a belief that petitioners had a dependent Permanent Establishment (PE) or Fixed Place PE in India Facts- The petitioners have filed the present petitions impugning notices issued by the Assessing Officer [AO] under Section 148 of the Income Tax Act, 1961 [Act] seeking to assess / reassess the income of the Petitioner/s for Assessment Years [AY] ranging from 2013-14 to 2017-18. Notably, the Petitione...