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2017 (1) TMI 1633 - AT - Income TaxValidity of reopening of assessment - assessee was making sales in India with the involvement of its Permanent Establishment (PE) in India and, accordingly, the profits attributable to such PE were chargeable to tax - whether No name of the assessee, business transactions and the relevant year appear in the reasons ? - Held that:- Initiation of reassessment is valid. Fixed place as well Agency Permanent establishment of all the GE overseas is established in India. Attribution of income to the PE should be 2.6% of the sales made by GE overseaes entities in India. Interest u/s 234B is not chargeable. See GE ENERGY PARTS INC. VERSUS ADIT, CIRCLE-1 (2) , INTERNATIONAL TAXATION, NEW DELHI. [2017 (2) TMI 780 - ITAT DELHI]
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