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 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
under
the provisions of the Act in the first place.
GE INDIA TECHNOLOGY CENTRE (P.) LTD. V. CIT 120101 327 ITR 456
(SC) explained.
PILOM ... deduct tax depending on the rate mentioned in the DTAA.
GE INDIA TECHNOLOGY CENTRE (R) LTD. v. CIT [20101 327 ITR 456
(SC) and VODAFONE
Reliance is placed on the
judgment in the case of GE India Technology Centre Private
Limited v. Commissioner of Income Tax and Another1 ... which is so chargeable." In fact, in
GE India Technology Centre (P) Ltd. (supra), the Apex
Court at para-14 has specifically recorded
Sharda Educational Trust , Greater ... vs Ito (Tds), International Taxation, ... on 5 May, 2022
IN THE
source was31 necessary.
6. In the case of GE India Technology Centre P.
Limited v. CIT reported in [2010] 327 ITR 456 (SC),
the ratio ... Supreme Court in the case of
Page No : 183 GE India Technology Centre P.
Limited v. CIT reported
normal course of
business is allowable as revenue loss:
(i) GE India Technology Center ... decision of Hon'ble Supreme Court in the case of GE India
Technology Centre Pvt. Ltd., 327 ITR 456. In this
order dated
09/07/2018 following the decision of GE Technology
Centre Pvt Ltd (supra) held that since no income was
chargeable in the hands
provision. Kindly refer Prithvi Information
Infra.
6.1 Supporting case laws:
6.1.1 GE India Technology Cen. P Ltd v. CIT
6.1.2 The issue in hand
High Court of Karnataka, namely,
the judgment of this Court in GE Technology (supra).
47. In all these cases, the "licence" that
