No Office, No Expatriates, No PE: ITAT Delhi Rejects Revenue’s Repeated PE Allegation

GE Global Parts & Products GMBH Vs ACIT (ITAT Delhi)

No Office, No Expats, No PE – ITAT Shuts Down Revenue’s Repeat Tactics in GE Global Case

Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in GE Global Parts & Products GMBH v. ACIT [Order dated 17 October 2025] reaffirmed that the Revenue cannot assume the existence of a Permanent Establishment (PE) merely by relying on findings from earlier years without examining the factual circumstances of the relevant assessment

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