IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘D’ NEW DELHI)

BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER ITA No. 1932/Del/2025 (A.Y. 2022-23)

GE Global Parts & Products Vs Assistant Commissioner of GMBH, Brown Boverit Strasse Income Tax, Circle 8, Baden, Switzerland International Taxation 1(3)(1) PAN: AAGCG3668K Civic Centre, Minto Road, New Delhi Appellant Respondent Assessee by Sh. Ajay Vohra, Sr. Adv., Sh. Aditya Vohra, Adv. & Sh. Arpit Goyal, CA Revenue by Sh. Saroj Kumar Dubey, CIT(DR)

Date of Hearing 28/08/2025 Date of Pronouncement 17 /10/2025 ORDER PER YOGESH KUMAR, U.S. JM:

The present appeal is filed by the Assessee against the Final Assessment Order dated 10/01/2025 passed u/s 143(3) r.w.Section144C(13) of the Income Tax Act, 1961 ('Act' for short)

pertaining to Assessment Year 2022-23.

2. The Ld. Counsel for the Assessee submitted that the solitary issue to be considered in the present Appeal is as to whether the Assessee had PE in India during the Assessment Year under consideration or not. The Ld. Counsel further submitted that the said issue has been considered by the Co-ordinate Bench of the Tribunal inAssessee’s