Domestic company paying DDT u/s. 115O doesn’t enter domain of DTAA: ITAT Pune

Piaggio Vehicles Private Limited Vs ACIT (ITAT Pune) ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nut-shell, domestic company doesn’t enter domain of DTAA at all. Facts- The assessee is a domestic company and is engaged in manufacture and sale of three and four wheeler motor vehicles for the transportation of goods and passengers. The case was selected for scrutiny through CASS. A reference was made to the Transfer Pricing Officer u/s 92CA(1) of the Act to determine the Arm’s Length Price of the internationa...