ITAT adjudicated transfer pricing and corporate guarantee fee...

ITAT adjudicated transfer pricing and corporate guarantee fee (CGF) disputes. For A.Y. 2015-16, the Tribunal remanded transfer pricing adjustments to the Assessing Officer (AO) for verification of internal and external Transactional Net Margin Method (TNMM) applied for export transactions with associated enterprises. Regarding CGF, the Tribunal allowed the claim at 0.19% for A.Y. 2015-16, consistent with judicial precedents. For A.Y. 2016-17, the Tribunal permitted CGF only up to 0.5%, disallowing the excess 0.12%. The revenue's grounds were partially allowed, with the matter being statistically remanded for further examination and providing the assessee an opportunity to present additional details.