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TMI Blog2017 (1) TMI 1679X X X X Extracts X X X X X X X X Extracts X X X X ..... (1) TMI 1679 - ITAT DELHI - TMI X X X X Extracts X X X X X X X X Extracts X X X X ..... E Packaged Power Inc., GE Canada Company, GE Multilin, GE Pacific Pte Ltd., GE Engine Services - Tri Remanufacturing Inc., G.E. Engine Services Mcallen LP, GE Accessory Services-Grand Prairie Inc., G.E. Aviation Materials LP, G.E. Engine Services Inc., G.E. Packaged Power Inc., GE Transportation Parts LLC, G.E. Caledonian Ltd., G.E. Engine Services- Tri Remanufacturing Inc., MRA System Inc., G.E. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , DR ORDER PER BENCH: These 138 appeals by different but connected assesses of GE group relate to the assessment years 2001-02 to 2008-09. 2. In all, following four issues have been raised in these appeals : - i. Challenge to reassessment ii. Permanent establishment iii. Attribution of income iv. Interest u/s 234B. 3. While some of the appeals do not involve the issue of reasses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 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. 6. As the facts and circumstances of these 138 appeals under consideration are similar to the lead case, we apply our above decision to the insta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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