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.
ITAT Mumbai deletes Rs 33.41 lakh addition under Section 56(2)(vii)(b), ruling Permanent Alternate Accommodation was given for tenancy surrender rights.
Explore the ITAT Mumbai ruling stating that the absence of an express irrevocability clause alone cannot defeat a Section 12AB trust renewal application.