High Court of Karnataka, namely, the
judgment of this Court in GE Technology [GE (India) Technology
Centre ... other hand, as has been noted in GE
Technology [GE (India) Technology Centre (P) Ltd. v. CIT,
(2010) 10 SCC 29] , at the heart
Ge (Shanghai) Power Technology Co. ... vs Assistant Commissioner Of Income Tax, ... on 7 April, 2022
Author: Rajiv Shakdher
Bench: Rajiv Shakdher ... 5799/2022 & CM No.17351/2022
M/S GE (SHANGHAI) POWER TECHNOLOGY CO. LTD.
......Petitioner
Through: Mr Deepak Chopra, Mr Ankul Goyal
Ge (Shanghai) Power Technology Co. ... vs Assistant Commissioner Of Income Tax, ... on 9 October, 2023
Author: Sanjay Kumar Sharma
Bench: Sanjay Kumar Sharma ... 5799/2022, CM APPL. 17351/2022
M/S GE (SHANGHAI) POWER TECHNOLOGY CO. LTD.
.....Petitioner
Through: Ms.Pratishtha Singh, Advocate
versus
ASSISTANT COMMISSIONER OF INCOME
Ge (Shanghai) Power Technology Co. ... vs Assistant Commissioner Of Income Tax, ... on 1 April, 2022
Author: Rajiv Shakdher
Bench: Rajiv Shakdher
$~15
* IN THE HIGH ... 5505/2022 & CM APPL. 16384/2022
M/S GE (SHANGHAI) POWER TECHNOLOGY
CO. LTD. ..... Petitioner
Through: Ms Pratishtha Singh and Mr Ankul
Goyal, Advs
DELHI
+ W.P.(C) 7644/2021
GE INDIA INDUSTRIAL PVT LTD. (AS SUCCESSOR IN
INTEREST TO GE INDIA TECHNOLOGY CENTRE PVT. LTD.,
NOW AMALGAMATED) ..... Petitioner ... notice dated 30.06.2021, has been
served on an entity i.e. GE India Technology Centre Pvt. Ltd, which is not in
existence anymore
excluded the following comparables
from the final list:-
A) M/s. Accentia Technology Pvt. Ltd.
B) M/s. I-Gate Global Solution ... Accentia Refer Commissioner of Income Tax-4 vs. GE
Technology Pvt. Ltd. India Business Services (P.) Ltd. [2023] 152
(Refer Substantial taxmann.com 517 (Delhi
held by Hon'ble SC in case
of GE India Technology Centre vs CIT (2010)(10 SCC 29) has
held that unless the payees ... held by Hon'ble SC in case of GE India Technology
Centre vs CIT (2010)(10 SCC 29) has held that unless the payees
Percy Pardiwala that this issue is covered by the decision in
GE Technology. We may record that a Double Taxation Avoidance
Agreement is a sovereign ... document between two countries. In GE
Technology, the apex court has held as follows (page 461 of 327
ITR):
"While deciding the scope
Percy Pardiwala that this issue is covered by the decision in
GE Technology. We may record that a Double Taxation Avoidance
Agreement is a sovereign ... document between two countries. In GE
Technology, the apex court has held as follows (page 461 of 327
ITR):
"While deciding the scope
2021 & CM No. 23916/2021
GE INDIA INDUSTRIAL PVT LTD. AS SUCCESSOR IN
INTEREST TO GE INDIA TECHNOLOGY CENTRE
PVT. LTD., NOW AMALGAMATED ..... Petitioner ... reason that
it was served on an entity i.e., GE India Technology Centre Pvt. Ltd., which
was not in existence at the relevant time
