No Tangible Evidence to Prove GE Steam Power has PE in India: Delhi HC sets aside Reassessment Notices

Delhi HC quashes reassessment notices against GE Steam Power - The Delhi High Court has quashed reassessment notices issued against GE Steam Power, finding no evidence to establish a "Permanent Establishment" (PE) in India for the relevant assessment years. The court emphasized that the determination of a PE is a fact-dependent inquiry for each assessment year and cannot be based on mere assumptions or extrapolations from previous years or survey findings without concrete material. This decision protects the company from retrospective tax demands where a PE was not demonstrably present.