Attribution of profit unsustainable in absence of Permanent Establishment in India

GE Energy Parts Inc Vs ACIT (ITAT Delhi) ITAT Delhi held that attribution of profit from offshore supply and services to the Permanent Establishment unsustainable as assessee didn’t have any Permanent Establishment in India in the assessment years under dispute. Facts- The assessees are non-resident corporate entities. The first named assessee is a tax resident of the USA. Whereas, the second named assessee is a tax resident of Switzerland. As stated by AO, both the assessees are engaged in the business of offshore supply of plants, equipment, spare parts and related offshore services to cus...