This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
GE overseas group companies having PE & DAPE in India, liable to tax in India
Case Law Details
- Case Name
- GE Energy Parts Inc Vs Commissioner Of Income Tax (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
Advertisement
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 negotiatio...
