The Court allowed the petitions and held that the reassessment proceedings under section 147 were invalid, as the Deputy Commissioner (IT) had categorized the assessee under all three types of permanent establishments i. e., service PE, fixed place PE, and dependent agent PE, without substantiating any of the necessary conditions. The Court found no evidence that the foreign enterprise rendered services in India through employees of its subsidiary or other personnel, nor was there material to show that the Indian subsidiary was authorized to, or actually did, conclude contracts for the assessee, ruling out a dependent agent PE. The mere discovery of the assessee’s seal during a survey was deemed irrelevant. The onus was on the Revenue to establish the existence of a PE, and statements recorded during the survey did not demonstrate this. The Indian subsidiary’s activities were limited to communication and consultancy support, which were preparatory or auxiliary in nature, and thus did not create a PE under the India-US DTAA. The Court concluded that the Revenue failed to establish any fixed place, service, or dependent agent PE, and that the finding of a PE was unsustainable in law.  High Court quashed the reassessment. SLP of the Revenue was dismissed.  (AY. 2012-13 to 2018-19)