https://www.taxtmi.com/caselaws?id=771786 Delhi HC quashed reassessment notices under Section 148 against non-resident companies, ruling that revenue authorities lacked tangible material to form belief that petitioners had Permanent Establishment in India. Court found no evidence of dependent PE or Fixed Place PE during relevant assessment years. Decision followed earlier favorable precedents in Grid Solutions OY, GE Hydro France, and GE Renewables Grid LLC cases. Petitioners' appeals were allowed. en-us Wed, 21 May 2025 00:00:00 +0530 Tue, 05 May 2026 10:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771786 Delhi HC quashed reassessment notices under Section 148 against non-resident companies, ruling that revenue authorities lacked tangible material to form belief that petitioners had Permanent Establishment in India. Court found no evidence of dependent PE or Fixed Place PE during relevant assessment years. Decision followed earlier favorable precedents in Grid Solutions OY, GE Hydro France, and GE Renewables Grid LLC cases. Petitioners' appeals were allowed. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771786