Reassessment Notices Quashed Due to Lack of Tangible Material for PE Allegation

GE Steam Power Systems Vs ACIT (Delhi High Court) The Delhi High Court dealt with a batch of petitions challenging notices issued under Section 148 of the Income Tax Act, 1961 for Assessment Years 2013–14 to 2017–18. The petitioners, non-resident entities forming part of a global power business group, had either filed returns declaring income such as Fees for Technical Services (FTS) taxable in India or, in some cases, claimed no taxable income and did not file returns for certain years. The reassessment notices were based on reasons recorded by the Assessing Officer (AO), primarily relyin...