ITAT Delhi Deletes Section 44BB Addition as Revenue Failed to Establish PE in India

Baker Hughes Energy Technology UK Ltd. Vs ACIT (ITAT Delhi) The assessee, a UK-based company, appealed against the assessment order dated 16.01.2025 passed under Sections 143(3) read with 144C for Assessment Year 2022-23. The principal dispute concerned whether the assessee had a Permanent Establishment (PE) in India and whether receipts from offshore supply of goods could be taxed under Section 44BB of the Income-tax Act. The assessee had entered into a contract with ONGC along with other consortium members for offshore supply of goods. It filed its return declaring income of Rs. 3,22,67,490....