Lack of India PE Evidence: Delhi HC Quashes Income Tax Reassessment

Ge Renewables Grid LLC Vs ACIT (International Taxation) Circle 1(1)(1) & Anr (Delhi High Court) Delhi High Court has delivered a significant blow to the Income Tax Department, quashing reassessment notices issued to GE Renewables Grid LLC (formerly Alstom Grid Inc/LLC) for Assessment Years 2013-14 to 2016-17. The court found that the Assessing Officer (AO) lacked tangible evidence to suggest that the US-based company had a Permanent Establishment (PE) in India during the relevant periods, a crucial prerequisite for taxing its business income in the country. Justice [Name of Judge(s) not av...