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2017 (1) TMI 1679 - ITAT DELHIValidity 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:- As decided in GE ENERGY PARTS INC. VERSUS ADIT, CIRCLE-1 (2) , INTERNATIONAL TAXATION, NEW DELHI. [2017 (2) TMI 780 - ITAT DELHI] - i. Initiation of reassessment is valid. ii. Fixed place as well Agency Permanent establishment of all the GE overseas is established in India. iii. Attribution of income to the PE should be 2.6% of the sales made by GE overseaes entities in India. iv. Interest u/s 234B is not chargeable.
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