GE Energy Parts Inc. v. Commissioner of Income Tax (International Taxation), ITA 621/2017, 21 December 2018 (High Court of Delhi)

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Summaries

Summary Under

GE U.S. companies had a PE in India based on the intensive negotiation of their employees in India in contact negotiations

The assesses were non-resident companies (“GE Overseas”) in the General Electric (GE) group who used the services of (i) expatriate employees...

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Summary Under

portion of profits attributable to marketing estimated at 26%

Various non-resident General Electric companies employed non-resident employees (the “expatriates”) in an office in India to secure customers...

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