Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI
260A of the Act comprise the General Electric group of companies: GE Energy Parts Inc (“GEP” hereafter); General Electric International Operations Company Inc. (“GEIOC” hereafter); GE India Industrial Pvt. Ltd and (GEIIPL). All challenge a common order of the Income Tax Appellate Tribunal (“ITAT”) which concluded that the appellant PE in India and were, therefore, liable to file income