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The ITAT upheld the assessee's cost allocation methodology based on headcount ratio, rejecting the TPO's alteration to salary expense ratio, as no new material warranted deviation from prior rulings in the assessee's AY 2017-18 case. The TPO's failure to select comparables before applying an alternative method was deemed impermissible. Disallowances under grounds 3 to 3.3 were deleted accordingly. Regarding CSR expenditure disallowance under section 80G, the Tribunal distinguished mandatory CSR contributions from voluntary donations, holding that CSR expenses qualify for deduction if other conditions under section 80G are met, absent any contrary Revenue allegations. Finally, the Tribunal directed the AO to grant depreciation at 25% on intangible assets' written down value, following precedent in the assessee's AY 2017-18 and AY 2018-19 cases, and allowed the additional ground raised by the assessee.
The ITAT upheld the assessee's cost allocation methodology based on headcount ratio, rejecting the TPO's alteration to salary expense ratio, as no new material warranted deviation from prior rulings in the assessee's AY 2017-18 case. The TPO's failure to select comparables before applying an alternative method was deemed impermissible. Disallowances under grounds 3 to 3.3 were deleted accordingly. Regarding CSR expenditure disallowance under section 80G, the Tribunal distinguished mandatory CSR contributions from voluntary donations, holding that CSR expenses qualify for deduction if other conditions under section 80G are met, absent any contrary Revenue allegations. Finally, the Tribunal directed the AO to grant depreciation at 25% on intangible assets' written down value, following precedent in the assessee's AY 2017-18 and AY 2018-19 cases, and allowed the additional ground raised by the assessee.
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