Pune ITAT Remands TP Issue on Spare Parts Exports, Allows Partial Relief on Corporate Guarantee Fee

DCIT Vs Piaggio Vehicles Pvt. Ltd. (ITAT Pune) The Income Tax Appellate Tribunal (ITAT), Pune Bench, has delivered a significant ruling in the case of the Deputy Commissioner of Income Tax (DCIT) versus Piaggio Vehicles Pvt. Ltd., addressing complex issues of transfer pricing for exported spare parts and the permissibility of corporate guarantee fee (CGF) payments to its parent entity. The Tribunal remanded the transfer pricing matter back to the Assessing Officer (AO) for re-evaluation and partially allowed the CGF expenses, setting a notable benchmark for the acceptable rate. The case revolv...