ITAT Mumbai rules that a Section 92CA reference must identify a transaction and the Transfer Pricing Officer cannot determine a Permanent Establishment.
ITAT Mumbai rules that SaaS subscription payments do not qualify as royalties under Section 9(1)(vi) or the India-Ireland tax treaty in the absence of a PE.
Explore the legal principles surrounding the condonation of delay in insurance appeals under Section 5 of the Limitation Act through a recent case study.