Order of Tribunal affirming the reassessment notice was up held High Court also affirmed the order of the Tribunal to recall the order. No new facts or circumstances existed in assessment to take a different view. (AY. 2009-10)
GE Nuovo Pignone S.P.A. v. CIT (IT ) [2024] 167 taxmann.com 351 / (2025) 477 ITR 659 (Delhi)(HC)
S. 147 : Reassessment – Survey-Non-resident-Permanent establishment Permanent agent- Dependant establishment-Attribution of profits – Reassessment notice was up held by the Tribunal – No substantial question of law – Appeal dismissed-Rejection of application for recall of the order was affirmed. [S. 148, 254(2), 260A, Art. 226]
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