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Documents citing Ge Energy Parts Inc. vs Cit (International Taxation), Delhi-I on 21 December, 2018

Grid Solutions Oy (Ltd) vs Assistant Commissioner Of Income Tax ... on 17 January, 2025

6. As a consequence of the above, the AO came to hold that the performance of senior functionaries of associated enterprises in India was monitored, controlled and managed by foreign companies of the GE Group, with Indian AEs playing a significant part in connection with the business of the foreign companies and being indelibly connected in the global business of the GE Group. The opinion with respect to escapement of income also appears to be founded on the decision rendered by this Court in GE Energy Parts Inc. vs. CIT (International Taxation), Delhi -15. The aforesaid judgment of the High Court was concerned with the challenge to reassessment initiated against various constituents of the GE Group pertaining to AY 2001-02. The reassessment action was upheld by the Income Tax Appellate Tribunal6 in terms of its judgment dated 27 January 2017 which was thereafter followed in subsequent AYs'. It is common ground that the reassessment action that formed the subject matter of that litigation emanated from a search and survey conducted in 2007 and on the basis of which assessments for AYs 2001-02 to 2008-09 came to be 5 2018 SCC OnLine Del 13256.
Delhi High Court Cites 27 - Cited by 0 - Y Varma - Full Document

Grid Solutions Oy (Ltd) vs Assistant Commissioner Of Income Tax ... on 17 January, 2025

6. As a consequence of the above, the AO came to hold that the performance of senior functionaries of associated enterprises in India was monitored, controlled and managed by foreign companies of the GE Group, with Indian AEs playing a significant part in connection with the business of the foreign companies and being indelibly connected in the global business of the GE Group. The opinion with respect to escapement of income also appears to be founded on the decision rendered by this Court in GE Energy Parts Inc. vs. CIT (International Taxation), Delhi -15. The aforesaid judgment of the High Court was concerned with the challenge to reassessment initiated against various constituents of the GE Group pertaining to AY 2001-02. The reassessment action was upheld by the Income Tax Appellate Tribunal6 in terms of its judgment dated 27 January 2017 which was thereafter followed in subsequent AYs'. It is common ground that the reassessment action that formed the subject matter of that litigation emanated from a search and survey conducted in 2007 and on the basis of which assessments for AYs 2001-02 to 2008-09 came to be 5 2018 SCC OnLine Del 13256.
Delhi High Court Cites 27 - Cited by 0 - Y Varma - Full Document

Grid Solutions Oy (Ltd) vs Assistant Commissioner Of Income Tax ... on 17 January, 2025

6. As a consequence of the above, the AO came to hold that the performance of senior functionaries of associated enterprises in India was monitored, controlled and managed by foreign companies of the GE Group, with Indian AEs playing a significant part in connection with the business of the foreign companies and being indelibly connected in the global business of the GE Group. The opinion with respect to escapement of income also appears to be founded on the decision rendered by this Court in GE Energy Parts Inc. vs. CIT (International Taxation), Delhi -15. The aforesaid judgment of the High Court was concerned with the challenge to reassessment initiated against various constituents of the GE Group pertaining to AY 2001-02. The reassessment action was upheld by the Income Tax Appellate Tribunal6 in terms of its judgment dated 27 January 2017 which was thereafter followed in subsequent AYs'. It is common ground that the reassessment action that formed the subject matter of that litigation emanated from a search and survey conducted in 2007 and on the basis of which assessments for AYs 2001-02 to 2008-09 came to be 5 2018 SCC OnLine Del 13256.
Delhi High Court Cites 27 - Cited by 0 - Y Varma - Full Document

Grid Solutions Oy (Ltd) vs Assistant Commissioner Of Income Tax ... on 17 January, 2025

6. As a consequence of the above, the AO came to hold that the performance of senior functionaries of associated enterprises in India was monitored, controlled and managed by foreign companies of the GE Group, with Indian AEs playing a significant part in connection with the business of the foreign companies and being indelibly connected in the global business of the GE Group. The opinion with respect to escapement of income also appears to be founded on the decision rendered by this Court in GE Energy Parts Inc. vs. CIT (International Taxation), Delhi -15. The aforesaid judgment of the High Court was concerned with the challenge to reassessment initiated against various constituents of the GE Group pertaining to AY 2001-02. The reassessment action was upheld by the Income Tax Appellate Tribunal6 in terms of its judgment dated 27 January 2017 which was thereafter followed in subsequent AYs'. It is common ground that the reassessment action that formed the subject matter of that litigation emanated from a search and survey conducted in 2007 and on the basis of which assessments for AYs 2001-02 to 2008-09 came to be 5 2018 SCC OnLine Del 13256.
Delhi High Court Cites 27 - Cited by 0 - Y Varma - Full Document

Grid Solutions Oy (Ltd) vs Assistant Commissioner Of Income Tax ... on 17 January, 2025

6. As a consequence of the above, the AO came to hold that the performance of senior functionaries of associated enterprises in India was monitored, controlled and managed by foreign companies of the GE Group, with Indian AEs playing a significant part in connection with the business of the foreign companies and being indelibly connected in the global business of the GE Group. The opinion with respect to escapement of income also appears to be founded on the decision rendered by this Court in GE Energy Parts Inc. vs. CIT (International Taxation), Delhi -15. The aforesaid judgment of the High Court was concerned with the challenge to reassessment initiated against various constituents of the GE Group pertaining to AY 2001-02. The reassessment action was upheld by the Income Tax Appellate Tribunal6 in terms of its judgment dated 27 January 2017 which was thereafter followed in subsequent AYs'. It is common ground that the reassessment action that formed the subject matter of that litigation emanated from a search and survey conducted in 2007 and on the basis of which assessments for AYs 2001-02 to 2008-09 came to be 5 2018 SCC OnLine Del 13256.
Delhi High Court Cites 27 - Cited by 0 - Y Varma - Full Document
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