2025 (5) TMI 285

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....'BLE MR. JUSTICE VIBHU BAKHRU AND HON'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 148 of the Income Tax Act, 1961 [Act] see....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....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 Alstom Group till 02.11.2015. However, the Alstom Grid business was acquired ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nts, 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 on GE Power India Ltd. which is a company incorporated in India and engaged in....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt 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 reasons were undated; survey report findings and the statements recorded were not supp....