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
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
M/S. Macrotech Developers Ltd (As ... vs Income Tax Officer (It) 3(2) (2) , Mumbai
decision in GE Technolgy. We may
record that a DTAA is a sovereign document between two
countries. In GE Technology, the Apex Court has held
High Court of Karnataka,
namely, the judgment of this Court in GE Technology (supra).
47. In all these cases, the "licence" that
Percy Pardiwala that this issue is
covered by the decision in GE Technology. We may record
IT(IT)A Nos.196 to 200/Bang/2023 ... that a DTAA is a sovereign document between two countries.
In GE Technology, the Apex Court has held as follows:
"7. .. While deciding
part of the activity was admittedly
carried out in India;
in GE India Technology Centre Private Limited
Vs. CIT17 , the Apex Court has held that ... decision in
GE Technolgy. We may record that a DTAA is a sovereign
document between two countries. In GE Technology, the
Apex Court has held
part of the activity was admittedly
carried out in India;
in GE India Technology Centre Private Limited
Vs. CIT17 , the Apex Court has held that ... decision in
GE Technolgy. We may record that a DTAA is a sovereign
document between two countries. In GE Technology, the
Apex Court has held
part of the activity was admittedly
carried out in India;
in GE India Technology Centre Private Limited
Vs. CIT17 , the Apex Court has held that ... decision in
GE Technolgy. We may record that a DTAA is a sovereign
document between two countries. In GE Technology, the
Apex Court has held
part of the activity was admittedly
carried out in India;
in GE India Technology Centre Private Limited
Vs. CIT17 , the Apex Court has held that ... decision in
GE Technolgy. We may record that a DTAA is a sovereign
document between two countries. In GE Technology, the
Apex Court has held
