2025 (5) TMI 285

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....496/2022 - -<br>Income Tax<br>HON&#39;BLE MR. JUSTICE VIBHU BAKHRU AND HON&#39;BLE MR. JUSTICE TEJAS KARIA For the Petitioner Through: Mr Aditya Vohra and Mr Shashvat Dhamija, Advocates. For the Respondents Through: Mr Ruchir Bhatia, SSC with Mr Anant and Mr P. Gupta, Advocates. VIBHU BAKHRU, J.(ORAL) 1. These petitions impugn notices issued by the Assessing Officer [AO] under Section ....

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....deployment of Power Grid transmission and distribution management software and applications as well as engineering services in relation to software products. The petitioner states that it is involved in engineering services and assembly of products that aid in transmission and distribution of power. 4. The petitioner was formally known as Alstom Grid Inc / Alstom Grid LLC and was a part of the ....

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..... The petitioner also sought the reasons recorded for reopening of the assessments, which were provided to the petitioner. The reasons recorded are similar in some of the material aspects. The AO's reasons to believe that the petitioner's income has escaped assessment is primarily based on a survey that was conducted under Section 133A (1) of the Act. The said survey was conducted on 06-07/06/2019....

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....he survey conducted on 06-07/06/2019 and observed that the petitioner had a Dependent PE and a Fixed Place PE in India. And, on the aforesaid basis alleged that the petitioner's business income attributable to its PE was chargeable to tax under the Act. 8. The petitioner objected to the initiation of the assessment proceedings under Section 147 of the Act on various grounds including that the r....